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for an administrative review of those matters (in the form of an
Appeals Office hearing). If the taxpayer is dissatisfied with an
Appeals Office determination regarding a collection action, the
taxpayer may seek judicial review of the administrative
determination in the Tax Court or Federal District Court, as
appropriate. See Davis v. Commissioner, 115 T.C. 35, 37 (2000);
Goza v. Commissioner, 114 T.C. 176, 179 (2000).
Sections 6320(a) and 6330(a) provide in pertinent part that
the Secretary shall notify a person in writing of his or her
right to an Appeals Office hearing regarding (1) a notice
required by section 6320 or (2) a final notice of intent to levy
by, among other methods, mailing such notice by certified or
registered mail to the person’s last known address. Further,
sections 6320(a)(3)(B) and 6330(a)(3)(B) provide that the
prescribed notification shall explain that the person has the
right to request an Appeals Office hearing during a specified 30-
day period.
Where the Appeals Office issues a determination letter to a
taxpayer following an administrative hearing regarding a notice
required by section 6320 and/or a final notice of intent to levy,
sections 6320(c) and 6330(d)(1) provide that the taxpayer shall
have 30 days following the issuance of such determination letter
to file a petition for review with the Tax Court or Federal
District Court, as appropriate. See Offiler v. Commissioner, 114
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Last modified: May 25, 2011