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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.
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