Michael Craig v. Commissioner - Page 24




                                        -24-                                          
                    (b) Right to Fair Hearing.--                                      
                         (1) In general.--If the person requests                      
                    a hearing under subsection (a)(3)(B), such                        
                    hearing shall be held by the Internal Revenue                     
                    Service Office of Appeals.                                        
                         *    *    *    *    *    *    *                              
                    (c) Matters Considered at Hearing.--In the case of                
               any hearing conducted under this section--                             
                         (1) Requirement of investigation.--The                       
                    appeals officer shall at the hearing obtain                       
                    verification from the Secretary that the                          
                    requirements of any applicable law or                             
                    administrative procedure have been met.                           
                         (2) Issues at hearing.--                                     
                              (A) In general.--The person                             
                         may raise at the hearing any                                 
                         relevant issue relating to the                               
                         unpaid tax or the proposed levy,                             
                         including--                                                  
                                   (i) appropriate                                    
                              spousal defenses;                                       
                                   (ii) challenges to                                 
                              the appropriateness of                                  
                              collection actions; and                                 
                                   (iii) offers of                                    
                              collection alternatives,                                
                              which may include the                                   
                              posting of a bond, the                                  
                              substitution of other                                   
                              assets, an installment                                  
                              agreement, or an offer-                                 
                              in-compromise.--                                        
                         *    *    *    *    *    *    *                              
                         (3) Basis for the determination.--The                        
                    determination by an appeals officer under                         
                    this subsection shall take into                                   
                    consideration--                                                   





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Last modified: May 25, 2011