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(A) the verification presented
under paragraph (1);
(B) the issues raised under
paragraph (2); and
(C) whether any proposed
collection action balances the need
for the efficient collection of
taxes with the legitimate concern
of the person that any collection
action be no more intrusive than
necessary.
(4) Certain issues precluded.--An issue
may not be raised at the hearing if--
(A) the issue was raised and
considered at a previous hearing
under section 6320 or in any other
previous administrative or judicial
proceeding; and
(B) the person seeking to
raise the issue participated
meaningfully in such hearing or
proceeding.
* * * * * * *
(d) Proceeding After Hearing.--
(1) Judicial review of determination.--
The person may, within 30 days of a
determination under this section, appeal such
determination--
(A) to the Tax Court (and the
Tax Court shall have jurisdiction
with respect to such matter); or
(B) if the Tax Court does not
have jurisdiction of the underlying
tax liability, to a district court
of the United States.
If a court determines that the appeal
was to an incorrect court, a person shall
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