Robert Hurford and Catherine Simone Hale - Page 7




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          (2000); Goza v. Commissioner, 114 T.C. 176, 179 (2000).  Section            
          6330 was enacted under the Internal Revenue Service                         
          Restructuring and Reform Act of 1998 (RRA 1998), Pub. L. 105-               
          206, sec. 3401, 112 Stat. 685, 746, and is effective with                   
          respect to collection actions initiated more than 180 days after            
          July 22, 1998, i.e., January 19, 1999.  See RRA 1998 sec.                   
          3401(d), 112 Stat. 750.                                                     
               Section 6330(c) prescribes the matters a person may raise              
          at an Appeals Office hearing.  In sum, section 6330(c) provides             
          that a person may raise collection issues such as spousal                   
          defenses, the appropriateness of the Commissioner’s intended                
          collection action, and possible alternative means of collection.            
          Section 6330(c)(2)(B) provides that the existence and amount of             
          the underlying tax liability can be contested at an Appeals                 
          Office hearing only if the person did not receive a notice of               
          deficiency for the taxes in question or did not otherwise have              
          an earlier opportunity to dispute the tax liability.  See Sego              
          v. Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner,            
          supra.  Section 6330(d) provides for judicial review of the                 
          administrative determination in either the Tax Court or Federal             
          District Court.                                                             











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