Fletcher H. Hyler - Page 14

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               In the Internal Revenue Service Restructuring and Reform Act           
          of 1998 (RRA 1998), Pub. L. 105-206, sec. 3401, 112 Stat. 746,              
          Congress enacted sections 6320 (pertaining to liens) and 6330               
          (pertaining to levies) to provide protections for taxpayers in              
          tax collection matters.  Section 6320 requires that the Secretary           
          notify a person who has failed to pay a tax liability of the                
          filing of a notice of lien under section 6323.  The notice                  
          required by section 6320 must be provided not more than 5                   
          business days after the day of the filing of the notice of lien,            
          pursuant to section 6320(a)(2).  Section 6320 further provides              
          that the person so notified may request administrative review of            
          the matter (in the form of a hearing) within 30 days beginning on           
          the day after the 5-day period.  Under section 6320(c), the                 
          hearing generally is to be conducted consistent with the                    
          procedures set forth in section 6330(c), (d), and (e).  Section             
          6330(c) permits the person notified to 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 person notified may contest the existence and amount of            
          the underlying tax liability at a hearing if that person did not            
          receive a notice of deficiency for the taxes in question or did             
          not otherwise have a prior opportunity to dispute the tax                   

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