Janet N. Moore - Page 6




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            746, Congress enacted new sections 6320 (pertaining to liens) and                          
            6330 (pertaining to levies) to provide due process protections                             
            for taxpayers in tax collection matters.  Sections 6320 and 6330                           
            are effective with respect to collection actions initiated more                            
            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 the 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. ___ (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–-                                                 






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