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objecting to a proposed collection action.
You proposed an alternative collection
resolution of an offer in compromise.
Appeals provided you opportunities to submit
the required forms and financial information
necessary to determine an adequate offer.
You have not responded.
. Without further cooperation, it is Appeals
[sic] determination that the proposed
collection action should not be restricted,
and balances the need for efficient
collection of taxes with the taxpayer’s
legitimate concern that any collection action
be no more intrusive than necessary.
Discussion
Respondent moves the Court to dismiss this case for lack of
jurisdiction. Respondent asserts that the Court lacks
jurisdiction to review the proposed levy determination because
sections 6320 and 6330 were not in effect when the liens were
filed against the property subject to the levy. We disagree with
respondent’s claim that we lack jurisdiction as to the proposed
levy determination.
The Internal Revenue Service Restructuring and Reform Act of
1998 (RRA 1998), Pub. L. 105-206, sec. 3401, 112 Stat. 685, 746,
by adding to the Code sections 6320 and 6330, granted the Court
jurisdiction to review the Commissioner’s determination as to the
propriety of a Federal tax lien or a proposed levy upon property.
Congress provided in RRA 1998 that the addition of sections 6320
and 6330 was to be effective for “collection actions initiated”
on or after January 19, 1999. Id. subsec. (d), 112 Stat. 750.
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Last modified: May 25, 2011