- 50 -
Cong., 2d Sess. (1998), 144 Cong. Rec. S4163 (daily ed. May 4,
1998). The Senate amendment provides without qualification that,
at a CDP hearing, taxpayers can raise “challenges to the
underlying tax liability as to existence or amount”. Id. In
response to the Senate amendment, Administration officials
expressed concern over the breadth of the proposed appeal rights,
noting, among other concerns, that, under the Senate amendment,
taxpayers could challenge even self-assessed (i.e., reported)
amounts at CDP hearings. See Statement of Administration Policy,
Office of Management and Budget (May 5, 1998), reprinted in Tax
Notes Today, 98 TNT 87-18 (May 6, 1998); letter from the Hon.
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 Daily Tax Report,
112 DTR at L-3 (June 11, 1998) (Department of Treasury views).16
The limiting language found in section 6330(c)(2)(B)
originated in the conference agreement on H.R. 2676. While the
accompanying committee report (the conference report), H. Conf.
Rept. 105-599, at 265-266 (1998), 1998-3 C.B. 747, 1019-1020,
reveals neither the impetus for, nor the intended effect of, the
16 See also 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 Daily Tax Report,
112 DTR at L-7 (June 11, 1998) (Department of Justice views).
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