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that a proper collection due process hearing was held through
correspondence. Respondent further contends that petitioner
failed to raise any other issues regarding the collection of the
tax liability and that the proposed levy should be allowed to
proceed. This case was submitted on this basis.
Discussion
1. Section 6330
Section 6330 entitles a taxpayer to notice and the
opportunity for a hearing before the process of collection by
lien and levy are taken. Upon request, a taxpayer is entitled to
a fair hearing before an impartial officer from the Internal
Revenue Service Office of Appeals. Sec. 6330(b)(1), (3). At the
hearing, the Appeals officer is required to verify that the
requirements of any applicable law or administrative procedure
have been met, and to consider any relevant issue relating to the
unpaid tax or proposed levy raised by the taxpayer. Sec.
6330(c)(1) and (2)(A).
A taxpayer may generally raise any relevant issue relating
to his or her unpaid tax liability or proposed levy during the
hearing. Relevant issues include an appropriate spousal defense,
challenges to the appropriateness of the collection action, and
offers of collection alternatives. Sec. 6330(c)(2)(A). The
taxpayer cannot raise issues relating to the underlying tax
liability if the taxpayer received a notice of deficiency or
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