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opportunity for administrative review of the matter in the form
of a hearing before the Internal Revenue Service Office of
Appeals. Sec. 6320(a)(2) and (3). Section 6320(b) and (c)
grants a taxpayer, who so requests, the right to a fair hearing
before an impartial Appeals officer, generally to be conducted in
accordance with the procedures described in section 6330(c), (d),
and (e).
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
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Last modified: May 25, 2011