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SEC. 6330(c). Matters Considered at Hearing.--In
the case of any hearing conducted under this section--
* * * * * * *
(2) Issues at hearing.--
(A) In general.--The person may raise
at the hearing any relevant issue relating to
the unpaid tax or proposed levy, including--
(i) appropriate spousal
defenses;
(ii) challenges to the
appropriateness of collection
actions; and
(iii) offers of collection
alternatives, which may include the
posting of a bond, the substitution
of other assets, an installment
agreement, or an offer-in-
compromise.
(B) Underlying liability.--The person
may also raise at the hearing challenges to
the existence or amount of the underlying tax
liability for any tax period if the person
did not receive any statutory notice of
deficiency for such tax liability or did not
otherwise have an opportunity to dispute such
tax liability.
Pursuant to section 6330(d)(1), within 30 days of the
issuance of the notice of determination, the taxpayer may appeal
that determination to this Court if we have jurisdiction over the
underlying tax liability. Van Es v. Commissioner, 115 T.C. 324,
328 (2000).
Although section 6330 does not prescribe the standard of
review that the Court is to apply in reviewing the Commissioner’s
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Last modified: May 25, 2011