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Therefore, she is not the “person” referred to in section
6330(a)(1); accordingly, section 6330 confers no hearing rights
upon her and respondent issued no notice to her, under section
6330(a). Although petitioner’s spouse is listed as a taxpayer on
the Form 12153 by which petitioner requested a hearing under
section 6330, she did not sign the document, and it in any event
confers no rights on her that do not exist under the statute.
Accordingly, the Appeals officer’s refusal to allow petitioner’s
spouse to participate in the hearing was not an abuse of
discretion.9
Conclusion
Having considered each of petitioner’s allegations of error,
we conclude that there was no abuse of discretion by the Appeals
officer. We hold that respondent may proceed with the proposed
levy. To reflect the foregoing,
Decision will be entered for
respondent.
9 In a separate order, we previously denied petitioner’s
spouse’s motion to join as a party to the proceedings before this
Court, on the grounds that she had failed to show that any
interests in property that she sought to protect were
inadequately protected by petitioner or would be impaired absent
joinder or intervention.
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Last modified: May 25, 2011