- 8 -
afford protections for taxpayers in lien situations. Section
6320(a)(1) establishes the requirement that the Secretary notify
in writing the person described in section 6321 of the filing of
a notice of lien under section 6323. This notice required by
section 6320 must be sent not more than 5 business days after the
notice of tax lien is filed and must advise the taxpayer of the
opportunity for administrative review of the matter in the form
of a hearing before the Internal Revenue Service Office of
Appeals. Sec. 6320(a)(2) and (3). Section 6320(b) and (c)
grants a taxpayer, who so requests, the right to a fair hearing
before an impartial Appeals officer, generally to be conducted in
accordance with the procedures described in section 6330(c), (d),
and (e).
Section 6330(c) addresses the matters to be considered at
the hearing:
SEC. 6330(c). Matters Considered at Hearing.--In
the case of any hearing conducted under this section--
(1) Requirement of investigation.--The
appeals officer shall at the hearing obtain
verification from the Secretary that the
requirements of any applicable law or
administrative procedure have been met.
(2) Issues at hearing.--
(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;
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011