Crevenne C. and Barbara A. Carrillo - Page 14

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          respects upon the premise of section 6331(d), forbidding                    
          collection by levy until the taxpayer has been furnished notice             
          of the opportunity for administrative review of the matter in the           
          form of a hearing before the IRS Office of Appeals.  Section                
          6330(b) grants a taxpayer who so requests the right to a fair               
          hearing before an impartial Appeals officer.                                
               Section 6330(c) addresses the matters to be considered at              
          the hearing:                                                                
                    SEC. 6330(c).  Matters Considered at Hearing.--In                 
               the case of any hearing conducted under this section--                 
                         (1) Requirement of investigation.--The                       
                    appeals officer shall at the hearing obtain                       
                    verification from the Secretary that the                          
                    requirements of any applicable law or                             
                    administrative procedure have been met.                           
                         (2) Issues at hearing.--                                     
                              (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.                              
                              (B) Underlying liability.--The person                   
                         may also raise at the hearing challenges to                  
                         the existence or amount of the underlying tax                
                         liability for any tax period if the person                   





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