Paul Everman - Page 10

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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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