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as stated in the committee reports and as discerned from the
setting in which that section was enacted, reveals that Congress
intended that a taxpayer be allowed under that section to dispute
a tax liability underlying a proposed levy whenever the taxpayer
did not have a prior opportunity to dispute that liability either
through the receipt of a notice of deficiency or otherwise.
The enactment of section 6330 followed more than a year of
Congressional investigations and hearings over the future of the
Internal Revenue Service (IRS), resulting in highly publicized
criticisms of the agency’s collection methods. Mesa Oil, Inc. v.
United States, 86 AFTR 2d 2000-7312, 2001-1 USTC par. 50,130 (D.
Colo. 2000). We know from the Senate report that the Senate
Finance Committee intended that section 6330 would establish
“formal procedures designed to insure due process where the IRS
seeks to collect taxes by levy”. S. Rept. 105-174, at 67 (1998),
1998-3 C.B. 537, 603. We also know from that report that the
committee believed that the addition of section 6330 would afford
to taxpayers in dealing with the IRS rights which were similar to
the rights afforded to all persons in dealing with any other
creditor. S. Rept. 105-174, supra at 67, 1998-3 C.B. at 603. To
this end, the committee declared, the Commissioner would by
virtue of section 6330 need henceforth to “afford taxpayers
adequate notice of collection activity and a meaningful hearing
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