Christine Whiting - Page 6

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          Sego v. Commissioner, supra at 610.  The Court reviews other                
          administrative determinations regarding the proposed levy action            
          for abuse of discretion.  Id.                                               
               In the present case, the only issue that petitioner raises             
          is that respondent failed to provide a section 6330 hearing to              
          petitioner.  Petitioner does not challenge the existence of the             
          underlying tax liability.  Accordingly, we review respondent’s              
          determination to proceed with the levy action for abuse of                  
          discretion.                                                                 
               Petitioner contends that it was an abuse of discretion for             
          respondent to treat the two telephone conversations between Mr.             
          Taggart and Appeals Officer Melick as a section 6330 hearing.  By           
          failing to provide a section 6330 hearing, petitioner argues,               
          respondent prevented petitioner from presenting the factual                 
          information and documentation that she had proposed to submit in            
          support of her offer in compromise.  Petitioner further asserts             
          that, because respondent did not consider petitioner’s factual              
          information and documentation, respondent lacked a sufficient               
          basis for determining that the levy action could proceed.                   
               In response, respondent contends that telephone conferences            
          are an acceptable format for section 6330 hearings and that the             
          two telephone conversations between Mr. Taggart and Appeals                 
          Officer Melick qualified as a section 6330 hearing.  According to           
          respondent, during the telephone conversations, Mr. Taggart and             






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