Marty J. Meehan - Page 6

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          Statutory and Regulatory Framework                                          
               Under section 6331(a), if any person liable to pay any tax             
          neglects or refuses to pay the tax within 10 days after notice              
          and demand, the Commissioner is authorized to collect the tax by            
          levy upon all property and rights to property belonging to such             
          person or on which there is a lien for payment of the tax.                  
          Section 6331(d) provides that at least 30 days before a levy of a           
          taxpayer’s property, the Commissioner must provide the taxpayer             
          with notice of intent to levy.                                              
               Section 6330 was added to the Code by the Internal Revenue             
          Service Restructuring and Reform Act of 1998 (RRA 1998), Pub. L.            
          105-206, sec. 3401, 112 Stat. 746, to provide taxpayers with the            
          right to an Appeals Office hearing to challenge the propriety of            
          a proposed levy.  See Parker v. Commissioner, 117 T.C. 63, 65               
          (2001).  If dissatisfied with the Appeals Office’s determination,           
          the taxpayer can appeal it to the Tax Court or a Federal district           
          court, as appropriate.  Sec. 6330(d).                                       
               Section 6330 is effective for collection actions that are              
          initiated on or after January 19, 1999; i.e., 180 days after its            

          relating to this contention.  We deem petitioner to have conceded           
          this issue.  See, e.g., Rule 331(b); Nicklaus v. Commissioner,              
          117 T.C. 117, 120 n.4 (2001).  Petitioner raises no appropriate             
          spousal defenses, challenges to the appropriateness of the notice           
          of Federal tax lien filing, or offers of collection alternatives.           
          Secs. 6320(c), 6330(c)(2)(A).  We likewise deem petitioner to               
          have conceded these matters.                                                

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