Don Weber II - Page 6

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               Sections 6320 (pertaining to Federal tax liens) and 6330               
          (pertaining to levies) establish procedures for administrative              
          and judicial review of certain collection actions.  As an initial           
          matter, the Commissioner is required to provide a taxpayer with             
          written notice that a Federal tax lien has been filed and/or that           
          the Commissioner intends to levy; the Commissioner is also                  
          required to explain to the taxpayer that such collection action             
          may be challenged on various grounds at an administrative                   
          hearing.  See Davis v. Commissioner, 115 T.C. 35, 37 (2000); Goza           
          v. Commissioner, 114 T.C. 176, 179 (2000).  Sections 6320(a)(2)             
          and 6330(a)(2) provide that the written notice described above              
          shall be given in person, left at the person’s dwelling or usual            
          place of business, or sent by certified or registered mail to               
          such person’s last known address.                                           
               When the Appeals Office issues a Notice Of Determination               
          Concerning Collection Action(s) to a taxpayer following an                  
          administrative hearing, section 6330(d)(1) provides that the                
          taxpayer has 30 days following the issuance of such notice to               
          file a petition for review with the Tax Court or, if the Tax                
          Court does not have jurisdiction over the underlying tax                    
          liability, with a Federal District Court.  See Offiler v.                   
          Commissioner, 114 T.C. 492, 498 (2000).  The procedure                      
          established under section 6330(d)(1) is made applicable to a                

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