Frank Lopez - Page 5




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          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 section               





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