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section 6331(d), forbidding collection by levy until the taxpayer
has received notice of the opportunity for administrative review
of the matter in the form of an Appeals Office hearing. Section
6330(b) grants a taxpayer who so requests the right to a fair
hearing before an impartial Appeals officer.
Section 6330(c) addresses the matters to be considered at
the hearing:
SEC. 6330(c). In the case of any hearing
conducted under this section--
(1) Requirement of investigation.--The
appeals officer shall at the hearing obtain
verification from the Secretary that the
requirements of any applicable law or
administrative procedure have been met.
(2) Issues at hearing.--
(A) In general.--The person may raise at
the hearing any relevant issue relating to
the unpaid tax or the proposed levy,
including--
(i) appropriate spousal defenses;
(ii) challenges to the
appropriateness of collection actions;
and
(iii) offers of collection
alternatives, which may include the
posting of a bond, the substitution of
other assets, an installment agreement,
or an offer-in-compromise.
(B) Underlying liability.--The person
may also raise at the hearing challenges to
the existence or amount of the underlying tax
liability for any tax period if the person
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Last modified: May 25, 2011