William A. Hoffman, Jr. - Page 3




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          determined that the Internal Revenue Service could proceed with             
          the proposed levy.                                                          
               The relevant parts of section 6330 provide:                            
               SEC. 6330 Notice and Opportunity for Hearing Before Levy.              
               (a) Requirement of notice before levy.--                               
               (1) In general.--No levy may be made on any property or                
               right to property of any person unless the Secretary has               
               notified such person in writing of their right to a hearing            
               under this section before such levy is made.                           
                   *       *       *       *       *      *       *                  
               (b) Right to a fair hearing.--                                         
               (1) In general.–- If the person requests a hearing                     
               under subsection (a)(3)(B), such hearing shall be held by              
               the Internal Revenue Service Office of Appeals.                        
                   *       *       *       *       *      *       *                  
               (c) Matters considered at hearing.--                                   
                   *       *       *       *       *      *       *                  
                    (2) Issues at hearing.--                                          
                    (A) In general.--The person may raise at the                      
                    hearing any relevant issue relating to the                        
                    unpaid tax or the proposed levy, including–-                      
                              (i) appropriate spousal                                 
                         defenses;                                                    
                              (ii) challenges to the                                  
                         appropriateness of collection                                
                         actions; and                                                 
                              (iii) offers of collection                              
                         alternatives, which may include                              
                         the posting of a bond, the                                   
                         substitution of other assets, an                             
                         installment agreement, or an offer-                          
                         in-compromise.                                               





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