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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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Last modified: May 25, 2011