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taxpayer written notice of his right to a section 6330 hearing at
least 30 days before any levy is begun.1
If a section 6330 hearing is requested, the hearing is to be
conducted by respondent’s Appeals Office (Appeals), and, at the
hearing, the Appeals officer or employee (without distinction,
Appeals officer) conducting it must verify that the requirements
of any applicable law or administrative procedure have been met.
Sec. 6330(b)(1), (c)(1). The taxpayer may raise at the hearing
any relevant issue relating to the unpaid tax or the proposed
levy. Sec. 6330(c)(2)(A). The taxpayer is entitled to propose
an offer in compromise or other alternative to immediate
collection. See sec. 6330(c)(2)(A)(iii). The taxpayer may
contest the existence or amount of the underlying tax liability
1 A taxpayer receiving a notice of Federal tax lien has
hearing rights similar to the hearing rights accorded a taxpayer
receiving a notice of intent to levy. See sec. 6320(c). Indeed,
the record in this case contains a Notice of Federal Tax Lien
Filing and Your Right to a Hearing under Section 6320, dated May
3, 2002, addressed to petitioner, and concerning his unpaid
Federal income tax for 1999 (the notice of Federal tax lien).
Respondent has proposed that we find that (1) the Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330, dated May 29, 2003 (notice of determination), which
we described supra in our Findings of Fact, relates only to the
Final Notice - Notice of Intent to Levy and Notice of Your Right
to a Hearing, issued Apr. 15, 2002, which we also described supra
in our Findings of Fact, and (2) the notice of determination was
issued under sec. 6330 only. Petitioner states that he does not
dispute those proposed findings of fact, and we find accordingly.
Therefore, we do not in this case concern ourselves with the
notice of Federal tax lien or any determination under secs. 6320
and 6330 in connection therewith.
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