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must describe the administrative review available to the
taxpayer, before proceeding with the levy. See also sec.
6330(a).
Section 6330 generally provides that the Commissioner cannot
proceed with collection by levy until the person has been given
notice and opportunity for an administrative review of the matter
(in the form of an Appeals Office hearing) and, if dissatisfied,
with judicial review of the administrative determination. See
Davis v. Commissioner, 115 T.C. 35, 37 (2000); Goza v.
Commissioner, 114 T.C. 176, 179-180 (2000).
Section 6330(b) describes the administrative review process,
providing that a taxpayer can request an Appeals hearing with
regard to a levy notice. At the Appeals hearing, the taxpayer
may raise certain matters set forth in section 6330(c)(2), which
provides, in pertinent part:
SEC. 6330(c). Matters Considered at Hearing.–-In the
case of any hearing conducted under this section--
* * * * * * *
(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
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