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under subsection (a)(3)(B), such hearing shall be held
by the Internal Revenue Service Office of Appeals.
(2) One hearing per period.--A person shall be
entitled to only one hearing under this section with
respect to the taxable period to which the unpaid tax
specified in subsection (a)(3)(A) relates.
(3) Impartial officer.--The hearing under this
subsection shall be conducted by an officer or employee
who has had no prior involvement with respect to the
unpaid tax specified in subsection (a)(3)(A) before the
first hearing under this section or section 6320. A
taxpayer may waive the requirement of this paragraph.
[Emphasis added.]
Section 6330(c) specifies the matters to be considered at the
hearing and in the determination by the Appeals officer.5
5SEC. 6330(c) provides:
(c) Matters Considered at Hearing.--In the case of
any hearing conducted under this section--
(1) Requirement of investigation.-–The appeals
officer shall at the hearing obtain verification from
the Secretary that the requirements of any applicable
law or administrative procedure have been met.
(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.
(continued...)
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Last modified: May 25, 2011