- 11 - OPINION I. Introduction Petitioner has assigned error to Appeals’ (Ms. Boudreau’s) determination that respondent may proceed to collect the unpaid tax by levy (the determination). Before addressing the assignment, we provide a general overview of the authority of the Secretary of the Treasury (Secretary) to collect unpaid taxes by levy, the procedures he must follow to do so, and our authority to review the determination. We also describe the Secretary’s authority to compromise a tax case. We then state the parties’ arguments and dispose of respondent’s objections to certain testimony of petitioner’s and Ms. Boudreau’s. Finally, we decide whether Ms. Boudreau erred in making the determination. We decide that she did not. II. Sections 6330 and 6331 Section 6331(a) authorizes the Secretary to levy against property and property rights where a taxpayer liable for taxes fails to pay those taxes within 10 days after notice and demand for payment is made. Section 6331(d) requires the Secretary to send the taxpayer written notice of the Secretary’s intent to levy, and section 6330(a) requires the Secretary to send thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011