Segudino and Delfa Razo - Page 5

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          Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3401,           
          112 Stat. 746, in order to afford taxpayers new procedural                  
          protections with regard to collection matters.  Section 6320                
          generally provides that the Secretary cannot proceed with                   
          collection of taxes by way of a lien on a taxpayer’s property               
          until the taxpayer has been notified in writing and provided with           
          an opportunity for an administrative review in the form of a                
          hearing before an impartial officer of the Internal Revenue                 
          Service Office of Appeals.  Sec. 6320(b).  Generally, hearings              
          under section 6320 are conducted in accordance with the                     
          procedural requirements set forth in section 6330(c).  Sec.                 
          6320(c).  At the hearing, the Appeals officer shall obtain                  
          verification that the requirements of any applicable laws and               
          administrative procedures have been met.  Sec. 6330(c)(1).                  
          Taxpayers may raise appropriate spousal defenses, challenges to             
          the appropriateness of the collection action, and offers of                 
          collection alternatives, which may include offers in compromise.            
          Sec. 6330(c)(2)(A)(iii).  In certain circumstances, taxpayers may           
          also challenge their underlying tax liability at the hearing.               
          Sec. 6330(c)(2)(B).                                                         
               In this case, petitioners do not dispute that the Appeals              
          officer obtained verification that the requirements of any                  
          applicable laws and administrative procedures had been met.  In             
          addition, petitioners do not dispute the existence or amount of             






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