John Thurman Horejs - Page 8

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          business days after the day of the filing of the notice of lien.            
          Sec. 6320(a)(2).  Section 6320 further provides that the person             
          may request administrative review of the matter (in the form of             
          an Appeals Office hearing) within 30 days beginning on the day              
          after the 5-day period.  Section 6320(c) provides that the                  
          Appeals Office hearing generally shall be conducted consistent              
          with the procedures set forth in section 6330(c), (d), and (e).             
          See, e.g., Goza v. Commissioner, 114 T.C. 176, 179 (2000).                  
               Section 6330(c) prescribes the matters that 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 the Tax              
          Court or a Federal District Court, as may be appropriate.                   

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