Raymond and Cynthia Turner-Simmons - Page 5

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          right to a section 6330 hearing at least 30 days before any                 
          levy is begun.3                                                             
               If a section 6330 hearing is requested, the hearing is                 
          to be conducted by Appeals, and, at the hearing, the Appeals                
          officer conducting it must verify that the requirements of                  
          any applicable law or administrative procedure have been                    
          met.  Sec. 6330(b)(1), (c)(2).  The taxpayer may raise at                   
          the hearing any relevant issue relating to the unpaid tax or                
          the proposed levy.  Sec. 6330(c)(2)(A).  The taxpayer may                   
          contest the existence or amount of the underlying tax                       
          liability at a hearing if the taxpayer 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,                  
          taking into account, among other things, collection                         
          alternatives proposed by the taxpayer and 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.  See sec. 6330(c)(3).                                       

               3  A taxpayer receiving a notice of Federal tax lien has               
          hearing rights similar to the hearing rights accorded a taxpayer            
          receiving a notice of intent to levy.  See sec. 6320(c).                    




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