- 23 -
before the IRS deprives them of their property.” Id. The
committee believed that these procedures would “increase fairness
to taxpayers.” Id.
The history of section 6330(c)(2) also reveals that the
Administration had during the legislative process voiced its
concern to two Members of Congress that the relevant term
included self-assessed liabilities and that those liabilities
should not be included within the breadth of that section. See
letter from L. Anthony Sutin, Acting Assistant Attorney General,
to the Hon. William V. Roth, Jr., Chairman, Committee on Finance,
U.S. Senate, and the Hon. William Archer, Chairman, Committee on
Ways and Means, U.S. House of Representatives (June 8, 1998),
reprinted in Tax Notes Today, 98 TNT 112-41 (June 11, 1998);
letter from Robert E. Rubin, Secretary of the Treasury, to the
Hon. William Archer, Chairman, Committee on Ways and Means, U.S.
House of Representatives (June 2, 1998), reprinted in Tax Notes
Today, 98 TNT 112-40 (June 11, 1998); cf. Statement of
Administration Policy, Office of Management and Budget (May 5,
1998), reprinted in Tax Notes Today, 98 TNT 87-18 (May 6, 1998).
The Administration wrote those letters after the Senate passed
the Senate’s version of section 6330, H.R. 2676, sec. 3401(b),
105th Cong., 2d Sess. (May 5, 1998), but before the conference
committee amended that version to read as enacted. The
conferees, however, opted not to change the relevant term to
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