Michael Norton - Page 6

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          request administrative review of the matter (in the form of a               
          hearing) within a 30-day period.  The hearing generally will be             
          conducted consistent with the procedures set forth in section               
          6330(c), (d), and (e).  Sec. 6320(c).                                       
               Pursuant to section 6330(c)(2)(A), a taxpayer may raise at             
          the section 6330 hearing any relevant issue with regard to the              
          Commissioner’s collection activities, including spousal defenses,           
          challenges to the appropriateness of the Commissioner’s intended            
          collection action, and alternative means of collection.  Sego v.            
          Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner, 114           
          T.C. 176, 180 (2000).  If a taxpayer received a statutory notice            
          of deficiency for the years in issue or otherwise had the                   
          opportunity to dispute the underlying tax liability, the taxpayer           
          is precluded from challenging the existence or amount of the                
          underlying tax liability.  Sec. 6330(c)(2)(B); Sego v.                      
          Commissioner, supra at 610-611; Goza v. Commissioner, supra at              
               When the Commissioner issues a determination regarding a               
          disputed collection action, section 6330(d) permits a taxpayer to           
          seek judicial review with the Tax Court or a U.S. District Court,           
          as is appropriate.  If the underlying tax liability is properly             
          at issue, we review that issue de novo.  Sego v. Commissioner,              
          supra at 610; Goza v. Commissioner, supra at 181.  If the                   
          validity of the underlying tax liability is not at issue, we                

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