Larry R. Johnston - Page 8

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          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;                  






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Last modified: May 25, 2011