Investment Research Associates, Inc. - Page 7

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          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 for            






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Last modified: May 25, 2011