Steven and Davina Sego - Page 8




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               In the Internal Revenue Service Restructuring and Reform Act           
          of 1998 (RRA 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 due process 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 due process hearing) and, if dissatisfied, with judicial             
          review of the administrative determination.  Section 6330(e)                
          generally provides for the suspension of the period of                      
          limitations on collection during the period that administrative             
          and judicial proceedings are pending and for 90 days thereafter.            
          Section 6330 is 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 6330(c) prescribes the matters that may be raised by                
          a taxpayer at an Appeals Office due process hearing in pertinent            
          part as follows:                                                            
                    SEC. 6330(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.                           





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