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the requirement that a person be provided with at least 30 days’
prior written notice of the Commissioner’s intent to levy before
collection may proceed. Section 6331(d) also indicates that this
notification should include a statement of available
administrative appeals. Section 6330(a) expands in several
respects upon the premise of section 6331(d), forbidding
collection by levy until the taxpayer has received notice of the
opportunity for administrative review of the matter in the form
of a hearing before the IRS Office of Appeals. Section 6330(b)
grants a taxpayer the right to a fair hearing before an impartial
Appeals officer upon request.
Section 6330(c) addresses the matters to be considered at
the hearing:
SEC. 6330(c). Matters Considered at Hearing.--In
the case of any hearing conducted under this section--
(1) Requirement of investigation.--The
appeals officer shall at the hearing obtain
verification from the Secretary that the
requirements of any applicable law or
administrative procedure have been met.
(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,
including--
(i) appropriate spousal defenses;
(ii) challenges to the
appropriateness of collection actions;
and
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