Leonard T. and Bonnie S. Whitfield - Page 6

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          amount of the unpaid tax and of the taxpayer’s right to a section           
          6330 hearing at least 30 days before the levy is begun.                     
               If a section 6330 hearing is requested, the hearing is to be           
          conducted by the Office of 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 also raise                    
          challenges to 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); see Montgomery v.                      
          Commissioner, 122 T.C. 1 (2004).                                            
               This Court has jurisdiction under section 6330 to review the           
          Commissioner’s administrative determinations.  Sec. 6330(d); see            
          Iannone v. Commissioner, 122 T.C. 287, 290 (2004).  Where, as               
          here, the validity of the underlying tax liability is not at                
          issue, we review the determination for abuse of discretion.  Sego           
          v. Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner,            
          114 T.C. 176, 183 (2000).  Whether an abuse of discretion has               
          occurred depends upon whether the exercise of discretion is                 
          without sound basis in fact or law.  See Freije v. Commissioner,            






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