Mehdi H. Hajiyani - Page 5

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               Section 6330(c)(2)(A) provides that, at the hearing, the               
          taxpayer may raise “any relevant issue relating to the unpaid tax           
          or the proposed levy” including spousal defenses, challenges to             
          the appropriateness of collection actions, and alternatives to              
          collection.  Section 6330(c)(1) requires that the Appeals officer           
          obtain verification that the requirements of any applicable law             
          or administrative procedure have been met.                                  
               When an Appeals officer issues a determination regarding a             
          disputed collection action, a taxpayer may seek judicial review             
          with the Tax Court or a District Court, as appropriate.  Sec.               
          6330(d); see Davis v. Commissioner, 115 T.C. 35, 37 (2000); Goza            
          v. Commissioner, 114 T.C. 176, 179 (2000).  The underlying tax              
          liability may be questioned if the taxpayer “did not receive any            
          statutory notice of deficiency for such tax liability or did not            
          otherwise have an opportunity to dispute such tax liability.”               
          Sec. 6330(c)(2)(B).  Where the validity of the underlying tax               
          liability is properly at issue, the Court will review the matter            
          de novo.  Sego v. Commissioner, 114 T.C. 604, 610 (2000).  Where            
          the validity of the underlying tax is not at issue, the Court               
          will review the Commissioner’s administrative determination for             
          an abuse of discretion.  Id.; Goza v. Commissioner, supra at 181-           
          182.  Petitioner had the opportunity to dispute the underlying              
          tax liabilities and did so in the deficiency proceeding.                    
          Therefore, the validity of the underlying tax liabilities may not           






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