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of the Secretary, and in the same manner as taxes. Sec.
6652(c)(4)(A).
Section 6331(a) provides that, if a person liable to pay any
tax neglects or refuses to do so within 10 days after notice and
demand, the Secretary can collect the tax by levy upon the
property belonging to the person, subject to the notice and fair
hearing requirements of sections 6330 and 6331(d). Pursuant to
section 6330(d)(1), after the administrative review process has
been completed and the Secretary has issued a notice of
determination, the person may appeal that determination within 30
days to this Court.4
3(...continued)
exceed the lesser of $10,000 or 5 percent of the gross
receipts of the organization for the year. In the case
of an organization having gross receipts exceeding
$1,000,000 for any year * * * the first sentence of
this subparagraph shall be applied by substituting
“$100” for “$20” and, in lieu of applying the second
sentence of this subparagraph, the maximum penalty
under this subparagraph shall not exceed $50,000.
4 Sec. 6330(d)(1) provides in full:
(1) Judicial review of determination.--The person
may, within 30 days of a determination under this
section, appeal such determination–-
(A) to the Tax Court (and the Tax Court
shall have jurisdiction to such hear matter);
or
(B) if the Tax Court does not have
jurisdiction of the underlying tax liability,
to a district court of the United States.
(continued...)
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