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corporation.” Petitioner did not provide any additional or
supporting information with the offer in compromise.
On June 24, 2003, respondent requested additional
information from petitioner with respect to his claim in the
offer in compromise that the tax liability belonged to the
corporation. Petitioner did not provide any additional
information.
On July 24, 2003, respondent issued to petitioner a Notice
Of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330. In the notice of determination, respondent
determined, in part, that: (1) All legal and procedural
requirements had been met; (2) petitioner’s offer in compromise
was properly rejected because petitioner did not provide any
additional information to support his position that the
discharged debt belonged to the corporation; and (3) the proposed
collection action was no more intrusive than necessary.
Discussion
Section 6330(a) provides that no levy may be made on any
property or right to property of any person unless the Secretary
has notified such person in writing of the right to a hearing
before the levy is made. If the taxpayer requests a hearing, a
hearing shall be held by the Internal Revenue Service Office of
Appeals. Sec. 6330(b)(1). At the hearing, a taxpayer may raise
any relevant issue, including appropriate spousal defenses;
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Last modified: May 25, 2011