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the form of an Appeals Office hearing), and if dissatisfied, with
judicial review of the administrative determination. See Davis
v. Commissioner, 115 T.C. 35, 37 (2000); Goza v. Commissioner,
114 T.C. 176, 179 (2000).
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.
Where the Appeals Office issues a determination letter to
the person following an administrative hearing regarding a lien
or levy action, sections 6320(c) (by way of cross-reference) and
6330(d)(1) provide that the person will have 30 days following
the issuance of the determination letter to file a petition for
review with the Tax Court or a Federal District Court. See
Offiler v. Commissioner, 114 T.C. 492, 498 (2000). Section
6330(d)(1) provides:
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Last modified: May 25, 2011