- 11 - Section 6330(c)(3), provides that a determination of the Appeals officer shall take into consideration the verification under section 6330(c)(1), the issues raised by the taxpayer, and whether the proposed collection action balances the need for the efficient collection of taxes with the legitimate concern of the person that any collection action be no more intrusive than necessary. Section 6330(d)(1) allows the taxpayer to appeal a determination to the Tax Court or a District Court. Section 6330(e)(1) suspends the levy action until the conclusion of the hearing and any judicial review of the determination. In order for a taxpayer to appeal a levy determination to this Court, pursuant to section 6330(d), the Rules of the Court require the taxpayer to file a petition for review of the determination. See Rule 331. That petition must contain clear and concise assignments of each and every error which the taxpayer alleges to have been committed in the determination, together with clear and concise statements of the facts on which the taxpayer bases each assignment of error. See Rule 331(b)(4) and (5). The Rules warn that any issue that is not raised by the taxpayer in the assignments of error shall be deemed conceded. Rule 331(b)(4); Lunsford Commissioner, supra at 190; Goza v. Commissioner, 114 T.C. 176, 178 (2000).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011