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raise as an issue or dispute the adjustments in the Form
4549-CG. The only issue raised by petitioners at the
section 6330 hearing was that they claimed that they had
already paid their 1995 income tax liability. Petitioners
presented no evidence beyond petitioner wife’s statements
that they had paid that liability.
On January 24, 2003, Appeals mailed to petitioners a
Notice of Determination Concerning Collection Action(s)
Under Section 6320 and/or 6330 (the determination). The
determination addresses the issues raised by petitioners in
protesting the levy, states that the levy is necessary to
ensure efficient collection of taxes, and confirms that
respondent has met the requirements of the applicable laws
and administrative procedures.
OPINION
I. Sections 6330 and 6331
Section 6331(a) authorizes the Secretary to levy
against property and property rights where a taxpayer liable
for taxes fails to pay those taxes within 10 days after
notice and demand for payment is made. Section 6331(d)
requires the Secretary to send written notice of an intent
to levy to the taxpayer, and section 6330(a) requires the
Secretary to send a written notice to the taxpayer of his
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