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than 180 days after July 22, 1998 (January 19, 1999). See RRA
1998 sec. 3401(d), 112 Stat. 750.
Section 6320(a)(1) requires the Commissioner to provide
notice to a person described in section 6321 of the filing of a
notice of lien under section 6323. Section 6320(a)(3) and (b)
provides that the person described in section 6321 is entitled to
notice of and opportunity for an administrative review of the
lien in the form of an Appeals Office due process hearing.
Section 6330 provides for a similar due process hearing where the
Commissioner has proposed to levy on the taxpayer's property.
Section 6320(c) adopts the procedures set forth in section
6330(c), (d), and (e) governing the issues that may be raised in
a due process hearing and the means for obtaining judicial review
of the matter. See Goza v. Commissioner, 114 T.C. 176 (2000).
Section 6330(d) provides for judicial review of an
administrative determination respecting a collection matter 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
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Last modified: May 25, 2011