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this sentence to mean that the Commissioner need send only one
notice of intent to levy for a taxable period. The Commissioner
may issue more than one notice of intent to levy to a taxpayer.
See sec. 301.6330-1(b)(2), Q&A-B2, Q&A-B4, Proced. & Admin. Regs.
Although more than one notice may be issued, the taxpayer is
still entitled to only one hearing for the relevant tax period.
Sec. 6330(b)(2); sec. 301.6330-1(b)(1), Proced. & Admin. Regs.
This interpretation is buttressed by the regulations under
section 6330, which provide:
Q-B2. Is the taxpayer entitled to a CDP hearing when
the IRS, more than 30 days after issuance of a CDP Notice
under section 6330 with respect to the unpaid tax and
periods, provides subsequent notice to that taxpayer that
the IRS intends to levy on property or rights to property of
the taxpayer for the same tax and tax periods shown on the
CDP Notice?
A-B2. No. Under section 6330, only the first pre-levy
or post-levy CDP Notice with respect to the unpaid tax and
tax periods entitles the taxpayer to request a CDP hearing.
If the taxpayer does not timely request a CDP hearing with
Appeals following that first notification, the taxpayer
foregoes the right to a CDP hearing with Appeals and
judicial review of Appeals’ determination with respect to
levies relating to that tax and tax period. The IRS
generally provides additional notices or reminders (reminder
notifications) to the taxpayer of its intent to levy when no
collection action has occurred within 180 days of a proposed
levy. Under such circumstances, a taxpayer may request an
equivalent hearing as described in paragraph (i) of this
section.
* * * * * * *
Q-B4. If the IRS sends a second CDP Notice under
section 6330 (other than a substitute CDP Notice) for a tax
period and with respect to an unpaid tax for which a CDP
Notice under section 6330 was previously sent, is the
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