Roy Watson - Page 6




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          II.  Section 6330                                                           
               Section 6330 generally provides that respondent cannot                 
          proceed with collection of taxes by way of levy on a taxpayer’s             
          property until the taxpayer has been given notice of and the                
          opportunity for an administrative review of the matter (in the              
          form of a section 6330(b) hearing).1  Section 6330(e) provides              
          for the suspension of the period of limitations on collection               
          while the hearing and any appeals are pending, and, in no event             
          shall such period of limitations expire before the 90th day after           
          the day on which there is a final determination in the hearing.             
               Section 6330(c) prescribes the matters that may be raised by           
          the taxpayer at a section 6330(b) hearing.  In pertinent part,              
          section 6330(c)(2)(B) provides:  “The person may also raise at              
          the hearing challenges to the existence or amount of the                    
          underlying tax liability for any tax period if the person did not           
          receive any statutory notice of deficiency for such tax                     
          liability”.                                                                 
               Section 6330(d) provides for judicial review of the                    
          determination resulting from the section 6330(b) hearing.                   



               1  In pertinent part, section 6330(a)(1) provides:                     
               No levy may be made on any property or right to                        
               property of any person unless the Secretary has                        
               notified such person in writing of their right to a                    
               hearing under this section before such levy is made.                   
               * * *                                                                  





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