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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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Last modified: May 25, 2011