Deavrah M. Chandler - Page 7

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          proceed with collection of taxes by way of a levy on a taxpayer’s           
          property until the taxpayer has been given notice of, and the               
          opportunity for, an administrative review of the matter.  The               
          statute specifically provides that “such hearing shall be held by           
          the Internal Revenue Service Office of Appeals.”  Sec.                      
          6330(b)(1).  A taxpayer is entitled to only one hearing with                
          respect to the taxable period(s) involved in the proposed lien or           
          levy.  Sec. 6330(b)(2).  If the taxpayer is dissatisfied with the           
          determination made after the hearing, judicial review of the                
          determination, such as that sought in this case, is available.              
          See generally Goza v. Commissioner, 114 T.C. 176, 179-181 (2000).           
               Section 6330(c) specifies the matters considered at the                
          hearing.  In this case, there is no dispute that the requirements           
          of applicable laws and procedures regarding the assessment have             
          been met, sec. 6330(c)(1), and there is no dispute with respect             
          to the underlying tax liability, sec. 6330(c)(2)(B).  Section               
          6330(c)(2)(A) provides:                                                     
                    (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.                             






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