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Sec. 6331(d). Such notice must also include a brief statement
setting forth, among other things, any available administrative
appeals. Sec. 6331(d)(4).
Section 6330 then establishes procedures for administrative
and judicial review of collection actions by levy. Specifically,
section 6330(a) requires a 30-day written notification to the
taxpayer of his or her right to an administrative hearing before
a levy may be made, including a statement of administrative
appeals available. Section 6330(b) provides that any hearing
requested by a taxpayer will be held by the IRS Office of Appeals
and conducted before an impartial officer. Section 6330(c)
establishes matters which can be considered at the administrative
hearing:
(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
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Last modified: May 25, 2011