Said M. Karara - Page 5

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          material fact exist, however, with respect to petitioner’s 1993             
          tax year.                                                                   
               I.  Section 6330 Hearing Prerequisites                                 
               If a taxpayer neglects or refuses to pay a Federal tax                 
          liability within 10 days of notice and demand, the Secretary is             
          authorized to collect such liability by levy on the taxpayer’s              
          property.  Sec. 6331(a).  Pursuant to section 6330(b), a taxpayer           
          has a right to a hearing before the Commissioner may levy.  We              
          first address whether respondent met the hearing prerequisites of           
          section 6330 with respect to petitioner’s 1993 and 1994 tax                 
          years.                                                                      
               Section 6330(b) provides that administrative hearings be               
          held by an impartial officer of the Internal Revenue Service                
          Office of Appeals.  If dissatisfied with the Appeals Office                 
          determination, a taxpayer may seek judicial review of the                   
          decision in this Court or a District Court of the United States             
          as applicable.  Sec. 6330(d).                                               
               The matters to be considered at the hearing are specified by           
          section 6330(c), which provides:  (1) The Appeals officer shall             
          obtain verification that the requirements of applicable law and             
          administrative procedure have been met; (2) certain issues may be           
          heard, including spousal defenses, appropriateness of collection            
          activities, and collection alternatives; and (3) a challenge to             
          the underlying liability may be raised if the taxpayer did not              






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