- 24 - address the Administration’s stated concern. The Senate version of section 6330(c)(2), see id., 144 Cong. Rec. S4163 (daily ed. May 4, 1998), provided (emphasis added): SEC. 6330(c)(2). Issues at hearing.--The person may raise at the hearing any relevant issue relating to the unpaid tax or the proposed levy, including-- (A) challenges to the underlying tax liability as to existence and amount. (B) appropriate spousal defenses, (C) challenges to the appropriateness of collection actions, and (D) offers of collection alternatives, which may include the posting of a bond, the substitution of other assets, an installment agreement, or an offer-in-compromise. Section 6330 as enacted provided (emphasis added): SEC. 6330(c)(2). Issues at hearing. (A) In general. The person may raise at the hearing any relevant issue relating to the unpaid tax or the proposed levy, including (i) appropriate spousal defenses; (ii) challenges to the appropriateness of collection actions; and (iii) offers of collection alternatives, which may include the posting of a bond, the substitution of other assets, an installment agreement, or an offer-in-compromise. (B) Underlying liability. The person may also raise at the hearing challenges to the existence or amount of the underlying tax liability for any tax period if the person did not receive any statutory notice of deficiency for such tax liability or did not otherwise have an opportunity to dispute such tax liability.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011