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Respondent contends that petitioners are collaterally
estopped from alleging irregularities in the assessment of their
tax liabilities for 1993-96. Respondent also contends that all
requirements have been met for respondent to collect taxes that
petitioners owe for 1993-2000.
Section 6330 (pertaining to levies) provides for
administrative and judicial review of certain collection actions.
The Commissioner is required to give a taxpayer written notice
that a Federal tax lien has been filed and/or that the
Commissioner intends to levy and to explain to the taxpayer that
such collection actions may be challenged on various grounds at
an administrative hearing. See Davis v. Commissioner, 115 T.C.
35, 37 (2000); Goza v. Commissioner, 114 T.C. 176, 179 (2000).
Section 6330(c)(1) requires the Appeals Office to obtain
verification that “the requirements of any applicable law or
administrative procedure have been met.” Section 6330(c)(2)
prescribes the matters that a person may raise at an
administrative hearing. Section 6330(c)(2)(A) provides that a
person may raise issues such as spousal defenses, the
appropriateness of the Commissioner's intended collection action,
and possible alternative means of collection. See Sego v.
Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner,
supra.
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