- 5 - the Service was willfully negligent when it failed to provide an Pre-Determination Evidentiary hearing and make available to me: a.) presentment of copies of all evidence used by the government against me; b.) meaningful hearing on all of the facts of this case; c.) notification of procedure, forms, or opportunity to refute the evidence against me (which is also the making of contentions of factual nature); d.) hearing before an independent and impartial hearing officer; and e.) opportunity to confront and cross-examine all adverse witnesses, for the creation of a complete defense and administrative record to support any subsequent appeal. OPINION I. Section 6331 Section 6331(a) provides that, if any person liable to pay any tax neglects or refuses to pay such tax within 10 days after notice and demand for payment, the Secretary is authorized to collect such tax by levy upon property belonging to the taxpayer. Section 6331(d) provides that the Secretary is obliged to provide the taxpayer with notice, including notice of the administrative appeals available to the taxpayer, before proceeding with collection by levy on property of the taxpayer.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011