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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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