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on the person's property, including notice of the available
administrative appeals.
In the Internal Revenue Service Restructuring and Reform Act
of 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 protections for taxpayers in
tax collection matters. These provisions generally provide that
the Commissioner cannot proceed with the collection of taxes by
way of a lien or levy on a person's property until the person has
been given notice of, and the opportunity for, an administrative
review of the matter (in the form of an Appeals Office hearing)
and, if dissatisfied, with judicial review of the administrative
determination in either the Tax Court or a Federal district
court.
In Goza v. Commissioner, 114 T.C. 176 (2000), we explained
that section 6330(c) provides for an Appeals Office hearing to
address collection issues such as spousal defenses, the
appropriateness of the Commissioner's intended collection action,
and possible alternative means of collection. Section
6330(c)(2)(B) provides that neither the existence nor the amount
of the underlying tax liability can be contested at an Appeals
Office hearing unless the taxpayer did not receive a notice of
deficiency for the taxes in question or did not otherwise have an
earlier opportunity to dispute such tax liability. The taxpayer
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