- 4 - 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.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011