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subsequent petition for innocent spouse relief. See Drake v.
Commissioner, 123 T.C. 320 (2004). Petitioner timely petitioned
this Court for judicial review of the notice of determination.9
Discussion
Section 6330(a) provides that no levy may be made on any
property or right to property of a person unless the Secretary
first notifies the person in writing of the right to a hearing
before the IRS Office of Appeals (Appeals Office).10 Section
6330(c)(1) provides that the Appeals officer must verify at the
hearing that applicable laws and administrative procedures have
been followed.11 Sec. 6330(c)(1). At the hearing, the person
9On Dec. 1, 2003, petitioner filed a timely Petition for
Levy Action Under Section 6330. Petitioner submitted an amended
petition on Jan. 18, 2005.
10SEC. 6330 NOTICE AND OPPORTUNITY FOR HEARING BEFORE LEVY.
(a) Requirement of Notice Before Levy.--
(1) In general.--No levy may be made on any
property or right to property of any person unless the
Secretary has notified such person in writing of their
right to a hearing under this section before such levy
is made. * * *
* * * * * * *
(b) Right to Fair Hearing.--
(1) In general.--If the person requests a hearing
* * *, such hearing shall be held by the Internal
Revenue Service Office of Appeals.
11Sec. 6330(c)(1) provides:
Requirement of investigation.--The appeals officer shall at
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