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the Treasury Secretary sent to the Chairman of the House Ways &
Means Committee (after Senate passage, with respect to the House-
Senate conference on the legislation), both identified two
principal concerns of overbreadth; namely, that under the Senate
version a taxpayer could dispute, in a section 6330 proceeding,
(i) tax liabilities that had been previously litigated or (ii)
tax liabilities that had been self-assessed. See Statement of
Administration Policy, Executive Office of the President (Office
of Management and Budget), on H.R. 2676 – Internal Revenue
Service Restructuring and Reform Act (Reported by the Senate
Committee on Finance)(May 5, 1998),1 reprinted in Tax Notes
Today, 98 TNT 87-18 (May 6, 1998); letter from Robert E. Rubin,
Secretary of the Treasury to William Archer, Chairman, Committee
1 The OMB Statement of Administration Policy states:
However, some of the new procedural provisions in the
reported bill may unintentionally make it easier for
noncompliant taxpayers to avoid paying their fair share
of taxes. For example, the bill would allow additional
appeals and court challenges before the IRS can collect
tax from a taxpayer who refuses to pay, even if the
taxpayer has voluntarily self-assessed the amount due
or a court has held that the taxpayer owes the tax.
[Emphasis added.]
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