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appropriate, R may proceed with the proposed collection
action.
Joyce M. Griggs, for petitioners.
Ross M. Greenberg, for respondent.
OPINION
RUWE, Judge: This case arises from a petition for judicial
review filed under section 6330(d)(1)(A).1 We have previously
decided that we have jurisdiction in this case. See Lunsford v.
Commissioner, 117 T.C. ___ (2001). For convenience, we combine
the facts, which are not in dispute, with our opinion.
Section 6331(a) authorizes the Commissioner to levy against
property and property rights where a taxpayer fails to pay taxes
within 10 days after notice and demand for payment is made.
Section 6331(d) requires the Secretary to send notice of an
intent to levy to the taxpayer, and section 6330(a) requires the
Secretary to send a written notice to the taxpayer of his right
to a hearing. Section 6330(b) affords taxpayers the right to a
“fair hearing” before an “impartial” IRS Appeals officer.
Section 6330(c)(1) requires the Appeals officer to obtain
verification that the requirements of any applicable law or
administrative procedure have been met. Section 6330(c)(2)(A)
1Unless otherwise indicated, all section references are to
the Internal Revenue Code currently in effect, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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