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required by section 6320 must be provided not more than 5
business days after the day of the filing of the notice of lien.
Sec. 6320(a)(2). Section 6320 further provides that the person
may request administrative review of the matter (in the form of
an Appeals Office hearing) within 30 days beginning on the day
after the 5-day period. Section 6320(c) provides that the
Appeals Office hearing generally shall be conducted consistent
with the procedures set forth in section 6330(c), (d), and (e).
Section 6330(c)(2) prescribes the matters that a person may
raise at an Appeals Office hearing. Under that section, a person
may raise any relevant issue related to the unpaid tax or noticed
lien, but may only contest the existence or amount of the
underlying tax liability if the person did not receive a notice
of deficiency for the tax liability or did not otherwise have an
opportunity to dispute the tax liability. Sec. 6330(c)(2)(B);
Sego v. Commissioner, 114 T.C. 604, 609 (2000); Goza v.
Commissioner, 114 T.C. 176, 180-181 (2000). Section 6330(d)
provides for judicial review of the administrative determination
in the Tax Court or a Federal District Court, as may be
appropriate. Where the underlying tax liability is not at issue,
the Court will review the Appeals officer’s determination for
abuse of discretion. Sego v. Commissioner, supra at 610.
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Last modified: May 25, 2011