Joyce E. Beery - Page 7

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          within 30 days beginning on the day after the 5-day period                  
          described above.  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) provides for review with respect to                    
          collection issues such as spousal defenses, the appropriateness             
          of the Commissioner's intended collection action, and possible              
          alternative means of collection.  Section 6330(d) provides for              
          judicial review of the administrative determination in the Tax              
          Court or Federal District Court, as appropriate.                            
               Section 6330(e) provides that levy actions and the running             
          of the period of limitations relating to collections (and other             
          actions) shall be suspended for the period during which an                  
          Appeals Office hearing, and appeals therein, are pending.4                  


               4  Sec. 6330(e)(1) provides:                                           
               SEC. 6330(e) Suspension of collections and statute of                  
               limitations.--                                                         
                    (1) In general.-–Except as provided in paragraph                  
               (2), if a hearing is requested under subsection                        
               (a)(3)(B), the levy actions which are the subject of                   
               the requested hearing and the running of any period of                 
               limitations under sec. 6502 (relating to collection                    
               after assessment), sec. 6531 (relating to criminal                     
               prosecutions), or sec. 6532 (relating to other suits)                  
               shall be suspended for the period during which such                    
               hearing, and appeals therein, are pending.  In no event                
               shall any such period expire before the 90th day after                 
               the day on which there is a final determination in such                
               hearing.  Notwithstanding the provisions of sec.                       
               7421(a), the beginning of a levy or proceeding during                  
                                                             (continued...)           




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