Brian and Tina Nicklaus - Page 6

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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,               

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