Johnnie L. Tillman - Page 6

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          petition in this Court.  See Chandler v. Commissioner, T.C. Memo.           
          2004-7 (filed this date).                                                   
                                     Discussion                                       
               The primary dispute in this case arises from an apparent               
          misunderstanding by petitioner and his representative of the                
          effect of sections 6320 and 6330.  Sections 6320 (pertaining to             
          liens) and 6330 (pertaining to levies) were enacted as part of              
          the Internal Revenue Service Restructuring and Reform Act of                
          1998, Pub. L. 105-206, sec. 3401, 112 Stat. 746, to provide new             
          procedural protections for taxpayers in collection matters.                 
          Section 6330 generally provides that the Commissioner may not               
          proceed with a collection of taxes by way of a levy on a                    
          taxpayer’s property until the taxpayer has been given notice of,            
          and the opportunity for, an administrative review of the matter.            
          The statute specifically provides that “such hearing shall be               
          held by the Internal Revenue Service Office of Appeals.”  Sec.              
          6330(b)(1).  A taxpayer is entitled to only one hearing with                
          respect to the taxable period involved in the proposed lien or              
          levy.  Sec. 6330(b)(2).  If the taxpayer is dissatisfied with the           
          determination made after the hearing, judicial review of the                
          determination, such as that sought in this case, is available.              
          See generally Goza v. Commissioner, 114 T.C. 176, 179-181 (2000).           
               Section 6330(c) specifies the matters considered at the                
          hearing.  In this case, there is no dispute that the requirements           






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