Johnnie L. Tillman - Page 7

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          of applicable laws and procedures regarding the assessment have             
          been met, sec. 6330(c)(1), and there is no dispute with respect             
          to the underlying tax liability, sec. 6330(c)(2)(B).  We review             
          respondent’s determination for abuse of discretion.  Goza v.                
          Commissioner, supra at 182.  Section 6330(c)(2)(A) provides:                
                    (A) In general.--The person may raise at the                      
               hearing any relevant issue relating to the unpaid tax                  
               or the proposed levy, including–-                                      
                         (i) appropriate spousal defenses;                            
                         (ii) challenges to the appropriateness of                    
                    collection actions; and                                           
                         (iii) offers of collection alternatives,                     
                    which may include the posting of a bond, the                      
                    substitution of other assets, an installment                      
                    agreement, or an offer-in-compromise.                             
          The only collection alternative offered by petitioner during the            
          process before Appeals was an offer in compromise for $100.                 
               Petitioner complains that there was no review within the               
          Appeals Office and that there was an abuse of discretion by the             
          Appeals officer in not referring the offer in compromise                    
          evaluation to IRS collection personnel.  In some cases,                     
          assistance from revenue officers may be sought.  See, e.g.,                 
          Van Vlaenderen v. Commissioner, T.C. Memo. 2003-346.  Petitioner            
          does not, however, have a right under section 6330 to more than             
          one hearing or to a hearing before anyone other than the Office             
          of Appeals.  Sec. 6330(b).                                                  








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