Keith and Cherie Orum - Page 15

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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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