- 5 - determination pursuant to section 6330 in which respondent determined that the lien filings constituted appropriate action and denied petitioner any relief. As stated, respondent did not conduct a CDP hearing with regard to the levy proposed in the Levy Letter, and respondent did not issue a notice of determination with regard thereto. On October 6, 2000, petitioner filed his petition herein in which petitioner challenges both the proposed levy and the proposed lien filings. OPINION Prior to collection of taxes by way of a levy on a taxpayer’s property, section 6330 requires that respondent give taxpayers notice of, and the opportunity for, administrative review of the proposed levy in the form of a CDP hearing. Section 6330(a) specifically provides that respondent shall notify a taxpayer of the right to a CDP hearing by mailing a notice of intent to levy to the taxpayer’s last known address, and the taxpayer has 30 days from the mailing of that notice to request a CDP hearing. If a timely request for a CDP hearing is made, respondent is required to make a determination of the issues raised at the hearing. Sec. 6330(c). Under section 6330(d), we have jurisdiction to review respondent’s determination with respect to issues raised at a CDP hearing only if a notice of determination pursuant to sectionPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011