Shuang-Di Sun Bennett - Page 10

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          certificate of deposit accounts at Bank of America with a                   
          combined balance ranging from approximately $10,000 to $12,050              
          during the year.  Most of the deposits into petitioner’s                    
          individual accounts came from checks written by Mr. Bennett from            
          their joint bank accounts.7                                                 
          I.  General Rules--Lien and Levy                                            
               Section 6331(a) authorizes the Commissioner to levy upon               
          property and property rights where a taxpayer liable for taxes              
          fails to pay them within 10 days after notice and demand for                
          payment.  Before the Commissioner can proceed with a levy,                  
          section 6331(d) requires the Secretary to send to the taxpayer a            
          written notice of intent to levy, and section 6330 entitles the             
          taxpayer to an administrative hearing conducted by an impartial             
          hearing officer from the Office of Appeals.                                 
               Section 6330(c)(2)(A) provides that the taxpayer may raise             
          any relevant issue with regard to the Commissioner’s collection             
          activities, including spousal defenses, challenges to the                   
          appropriateness of the intended collection action, and                      
          alternative means of collection.  Additionally, the taxpayer may            
          challenge the existence or amount of the underlying tax                     
          liability, including a liability reported by the taxpayer on an             

               7  Petitioner earned $608 of the taxable interest in 1998              
          from her accounts at Bank of America.                                       

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Last modified: May 25, 2011