Simon L. and Patricia M. Richard - Page 9

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          administrative procedure have been met.  Section 6330(c)(2)(A)              
          provides that the taxpayer may raise "any relevant issue related            
          to the unpaid tax" including spousal defenses, challenges to the            
          appropriateness of collection actions, and alternatives to                  
          collection.  The taxpayer may also raise challenges to the                  
          existence or amount of the underlying tax liability if he did not           
          receive a statutory notice of deficiency with respect to the                
          underlying tax liability or did not otherwise have an opportunity           
          to dispute that liability.  Sec. 6330(c)(2)(B).                             
               At the conclusion of the hearing, the Appeals officer must             
          determine whether and how to proceed with collection and shall              
          take into account (I) the verification that the requirements of             
          any applicable law or administrative procedure have been met,               
          (ii) the relevant issues raised by the taxpayer, (iii) challenges           
          to the underlying tax liability by the taxpayer, where permitted,           
          and (iv) whether any proposed collection action balances the need           
          for the efficient collection of taxes with the legitimate concern           
          of the taxpayer that the collection action be no more intrusive             
          than necessary.  Sec. 6330(c)(3).                                           
               We have jurisdiction to review the Appeals officer's                   
          determination where we have jurisdiction over the type of tax               
          involved in the case.  Sec. 6330(d)(1)(A); see Iannone v.                   
          Commissioner, 122 T.C. 287, 290 (2004).  Generally, we may                  
          consider only those issues that the taxpayer raised during the              






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