Barry L. Moore - Page 12




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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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