- 7 - required by section 6320(a)(1) is to be provided not more than 5 business days after the day of the filing of the notice of lien. Section 6320(a)(3) describes the information required to be included in the notice described in section 6320(a)(1). Section 6320(a)(3)(B) provides that the notice shall include “the right of the person to request a hearing during the 30-day period beginning on the day after the 5-day period described in paragraph (2).” B. Right to an Administrative Hearing Section 6320(b)(1) provides that a person requesting a hearing under subsection (a)(3)(B) is entitled to a hearing in respondent’s Appeals Office. Section 6320(b)(2) imposes a qualification on subsection (b)(1) by providing that “A person shall be entitled to only one hearing under this section with respect to the taxable period to which the unpaid tax specified in subsection (a)(3)(A) relates.” Section 6320(c) provides that an Appeals Office hearing generally shall be conducted consistent with the procedures set forth in section 6330(c), (d), and (e). C. Judicial Review and Tax Court Jurisdiction When the Appeals Office issues a notice of determination to a taxpayer following an administrative hearing regarding a lien or levy action, sections 6320(c) (by way of cross-reference) and 6330(d)(1) provide that the taxpayer will have 30 days following the issuance of a notice of determination to file a petition forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011