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Section 6330(a) provides in pertinent part that the
Secretary shall notify a person in writing of his or her right to
an Appeals Office hearing regarding a final notice of intent to
levy by mailing such notice by certified or registered mail to
such person at his or her last known address. Section 6330(a)(2)
provides that the prescribed notice shall be provided not less
than 30 days before the day of the first levy with respect to the
amount of the unpaid tax for the taxable period. Further,
section 6330(a)(3)(B) provides that the prescribed notice shall
explain that the person has the right to request an Appeals
Office hearing during that 30-day period.
Where the taxpayer has timely requested an Appeals Office
hearing and the Appeals Office has issued a notice of
determination to the taxpayer regarding a proposed levy action,
section 6330(d)(1) provides that the taxpayer will have 30 days
following the issuance of such notice to file a petition for
review with the Tax Court or Federal District Court, as may be
appropriate. See Offiler v. Commissioner, 114 T.C. 492, 498
(2000). Notably, there is no provision analogous to section
6213(f) in section 6330 that tolls the statutory period for
filing a timely petition for lien or levy action for the period
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Last modified: May 25, 2011