- 10 - 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, 114Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011