Aaron T. and Linda K. Ball - Page 5

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          administrative review available to the taxpayer, before                     
          proceeding with the levy.  See also sec. 6330(a).                           
               Section 6330(b) describes the administrative review process,           
          providing that a taxpayer can request an Appeals hearing with               
          regard to a levy notice.  At the Appeals hearing, the taxpayer              
          may raise certain matters set forth in section 6330(c)(2), which            
                    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 the proposed levy,                              
                              (i)  appropriate spousal                                
                              (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-                                   
                         (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                 

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Last modified: May 25, 2011