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Section 6330 applies to collection actions initiated more than
180 days after July 22, 1998 (January 19, 1999, and thereafter).
See RRA 1998 sec. 3401(d), 112 Stat. 750.
Section 6330(a)(1) entitles a taxpayer to only one notice
for a specific tax liability due for a taxable period. Section
6330(a) and (b) restricts a taxpayer’s statutory right to request
a collection due process hearing before the Office of Appeals to
the 30-day period following the date of the notice. See also
sec. 301.6330-1T(b) and (c), Temporary Proced. & Admin. Regs., 64
Fed. Reg. 3405 (Jan. 19, 1999). On February 1, 1999, petitioner
was notified in writing of her right to request a collection due
5(...continued)
(B) Underlying liability.-–The person may
also raise at the hearing challenges to the
existence or amount of the underlying tax
liability for any tax period if the person did not
receive any statutory notice of deficiency for such
tax liability or did not otherwise have an
opportunity to dispute such tax liability.
(3) Basis for the determination.-–The
determination by an appeals officer under this
subsection shall take into consideration–-
(A) the verification presented under
paragraph (1);
(B) the issues raised under paragraph (2);
and
(C) whether any proposed collection action
balances the need for the efficient collection of
taxes with the legitimate concern of the person
that any collection action be no more intrusive
than necessary.
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Last modified: May 25, 2011