William C. Eberhardt, Jr. and Susan A. Eberhardt - Page 12

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          administration.  On December 12, 2002, Ms. Clinger notified                 
          petitioners that respondent was rejecting their OIC.                        
               On January 9, 2003, Ms. Clinger sent petitioners a Notice of           
          Determination Concerning Collection Action Under Section 6330               
          sustaining respondent's proposed levy as the appropriate means of           
          collecting petitioners' unpaid liability for the 1995 tax year.             
          She also sent petitioners another copy of the letter rejecting              
          their OIC.  Additionally, Ms. Clinger sent petitioners a Notice             
          of Full Disallowance--Final Determination denying petitioners'              
          request for an abatement of interest on their 1995 deficiency               
          assessment.                                                                 
                                     Discussion                                       
               Section 6330(c) prescribes the matters that a person may               
          raise at an Appeals Office hearing.  Section 6330(c)(2)(A)                  
          provides that a person may raise collection issues such as                  
          spousal defenses, the appropriateness of the Commissioner's                 
          intended collection action, and possible alternative means of               
          collection.  See Sego v. Commissioner, 114 T.C. 604, 609 (2000);            
          Goza v. Commissioner, 114 T.C. 176, 180 (2000).  In addition,               
          section 6330(c)(2)(B) establishes the circumstances under which a           
          person may challenge the existence or amount of his or her                  
          underlying tax liability.  Section 6330(c)(2)(B) provides:                  









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