William B. Meyer - Page 7




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            Section 6330(c) prescribes the matters that may be raised by                               
            a taxpayer at an Appeals Office hearing.  In sum, section 6330(c)                          
            provides that a taxpayer may raise collection issues such as                               
            spousal defenses, the appropriateness of the Commissioner's                                
            intended collection action, and possible alternative means of                              
            collection.  Section 6330(c)(2)(B) provides that the existence                             
            and amount of the underlying tax liability can be contested at an                          
            Appeals Office hearing if the taxpayer did not receive a notice                            
            of deficiency for the taxes in question or did not otherwise have                          
            an opportunity to dispute such tax liability.  See Sego v.                                 
            Commissioner, 114 T.C. 604 (2000); Goza v. Commissioner, supra.                            
                  Section 6330(d) provides for judicial review of the                                  
            Commissioner's administrative determination in pertinent part as                           
            follows:                                                                                   
                  SEC. 6330(d).  Proceeding After Hearing.--                                           
                        (1) Judicial review of determination.-–The person                              
                  may, within 30 days of a determination under this                                    
                  section, appeal such determination–-                                                 
                              (A) to the Tax Court (and the Tax Court shall                            
                        have jurisdiction to hear such matter); or                                     
                              (B) if the Tax Court does not have                                       
                        jurisdiction of the underlying tax liability, to a                             
                        district court of the United States.                                           
                  If a court determines that the appeal was to an incorrect                            
                  court, a person shall have 30 days after the court                                   
                  determination to file such appeal with the correct court.                            
                  Section 6330(d) imposes certain procedural prerequisites on                          
            judicial review of collection matters.  Much like the Court's                              





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