- 9 -
Victoria Osborn. The Court rejected Ms. Osborn's proposed
testimony after a brief voir dire revealed that she did not have
any firsthand knowledge regarding petitioner's above-described
Tax Court cases assigned docket Nos. 37347-84, 29751-88, 21830-
89, and 20618-90.
Discussion
Section 6331(a) provides that if any person liable to pay
any tax neglects or refuses to pay such tax within 10 days after
notice and demand for payment, the Secretary is authorized to
collect such tax by levy upon property belonging to the taxpayer.
Section 6331(d) provides that the Secretary is obliged to provide
the taxpayer with notice before proceeding with collection by
levy on the taxpayer's property, including notice of the
administrative appeals available to the taxpayer.
In the Internal Revenue Service Restructuring and Reform Act
of 1998, Pub. L. 105-206, sec. 3401, 112 Stat. 685, 746, Congress
enacted new sections 6320 (pertaining to liens) and 6330
(pertaining to levies) to provide protections for taxpayers in
tax collection matters. Section 6330 generally provides that the
Commissioner cannot proceed with the collection of taxes by way
of a levy on a taxpayer's property until the taxpayer has been
given notice of, and the opportunity for, an administrative
review of the matter (in the form of an Appeals Office hearing);
if dissatisfied with the outcome of such hearing, the taxpayer
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