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that the owner specifies). The Commissioner must comply with the
request unless the Commissioner determines (and notifies the
owner within such period) that compliance would not be in the
best interests of the United States. Sec. 6335(f).
The applicable regulation requires that any request under
section 6335(f) be made in writing to the group manager of the
revenue officer whose signature is on the notice of levy. Sec.
301.6335-1(d)(2)(i), Proced. & Admin. Regs.10 The regulation
provides that the request to sell seized property should include
the following information:
(A) The name, current address, current home and
work telephone numbers and any convenient times to be
contacted, and taxpayer identification number of the
owner making the request;
(B) A description of the seized property that is
the subject of the request;
(C) A copy of the notice of seizure, if available;
(D) The period within which the owner is
requesting that the property be sold; and
(E) The signature of the owner or duly authorized
representative. * * * [Sec. 301.6335-1(d)(2)(ii),
Proced. & Admin. Regs.]
The group manager must respond in writing to a request for sale
of seized property as soon as practicable after receipt of such
request and in no event later than 60 days after receipt of the
10 If the owner does not know the group manager’s name or
address, the owner may send the request to the revenue officer,
marked for the attention of his or her group manager. Sec.
301.6335-1(d)(2)(i), Proced. & Admin. Regs.
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