-7-
Jacklin v. Commissioner, 79 T.C. 340, 344 (1982). The party
opposing summary judgment must set forth specific facts which
show that a question of genuine material fact exists and may not
rely merely on allegations or denials in the pleadings. See
Grant Creek Water Works, Ltd. v. Commissioner, 91 T.C. 322, 325
(1988); Casanova Co. v. Commissioner, 87 T.C. 214, 217 (1986).
Section 6330 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 Appeals Office.4 Section 6330(c)(1) provides that the
Appeals officer must verify at the hearing that applicable laws
and administrative procedures have been followed.5 The Appeals
4SEC. 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.
5Sec. 6330(c)(1) provides:
(1) Requirement of investigation.--The appeals
officer shall at the hearing obtain verification from
(continued...)
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