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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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Last modified: May 25, 2011