Leonard Parker - Page 4




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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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