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have been met. Sec. 6330(b)(1), (c)(1). Section 6330(c)
prescribes the matters that a taxpayer may raise at an Appeals
Office hearing. Section 6330(c)(2)(A) provides that a taxpayer
may raise at the hearing “any relevant issue relating to the
unpaid tax or proposed levy”, including spousal defenses and
collection alternatives. Additionally, the taxpayer may
challenge the existence or amount of the underlying tax liability
if the taxpayer “did not receive any statutory notice of
deficiency for such tax liability or did not otherwise have an
opportunity to dispute such tax 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).
Section 6330(d)(1) provides that if the Appeals Office
issues a notice of determination to the taxpayer following a
section 6330 hearing regarding a levy action, then the taxpayer
will have 30 days following the issuance of such determination
letter to file a petition for review with this Court or a Federal
District Court, as may be appropriate. See Offiler v.
Commissioner, 114 T.C. 492, 498 (2000).
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Last modified: May 25, 2011