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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
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Last modified: May 25, 2011