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(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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