Michael W. Bethea - Page 7

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          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).  Matters Considered at Hearing.--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 did not receive any statutory notice                
                           of deficiency for such tax liability or did                
                           not otherwise have an opportunity to                       
                           dispute such tax liability.                                







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Last modified: May 25, 2011