David and Ludmila Klet - Page 7

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          the hearing.  As relevant here, a taxpayer may challenge the                
          appropriateness of the Commissioner’s collection actions and                
          submit offers of collection alternatives.  Sec. 6330(c)(2)(A)(ii)           
          and (iii).  The taxpayer may also raise challenges to the                   
          existence or amount of the underlying tax liability if the                  
          taxpayer did not receive a statutory notice of deficiency for the           
          liability or did not otherwise have an opportunity to dispute the           
          tax liability.  Sec. 6330(c)(2)(B).                                         
               Once the Appeals officer has issued a determination                    
          regarding the disputed collection action, the taxpayer may seek             
          judicial review in the Tax Court or, if the Tax Court lacks                 
          jurisdiction in the matter, in a U.S. District Court.  Sec.                 
          6330(d).  Where the validity of the underlying tax liability is             
          properly at issue, the Court will review the matter on a de novo            
          basis.  However, where the validity of the underlying tax                   
          liability is not properly at issue, the Court will review the               
          Commissioner’s administrative determination for abuse of                    
          discretion.  Sego v. Commissioner, 114 T.C. 604, 610 (2000).                
               The Tax Court has jurisdiction in a lien proceeding,                   
          instituted under section 6330(d)(1), to determine whether a                 
          petitioner’s unpaid liabilities were discharged in bankruptcy.              
          Washington v. Commissioner, 120 T.C. 114, 120-121 (2003).                   
               In this case, petitioners’ only challenge with respect to              
          the collection notice is a claim that the bankruptcy court had              






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