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testified that he received a notice from respondent prior to the
November 6, 2003, notices, but he did not recall the nature of
that notice.
II. Collection Hearing
Section 6320 provides that the Secretary shall furnish the
person described in section 6321 with written notice (i.e., the
hearing notice) of the filing of a notice of lien under section
6323. Section 6320 further provides that the taxpayer may
request administrative review of the matter (in the form of a
hearing) within a 30-day period.
Section 6320(b)(2) states that a taxpayer shall be entitled
to only one hearing with respect to the taxable period to which
the unpaid tax relates. Taxpayers are entitled to this hearing
only if they request administrative review of the matter within
the 30-day period following the receipt of the first notice of
lien with regard to the unpaid tax. Sec. 301.6320-1(b)(2), Q&A-
B4, Proced. & Admin. Regs.;4 see also Orum v. Commissioner, supra
4 Sec. 301.6320-1(b)(2), Q&A-B4, Proced. & Admin. Regs.,
states:
Q-B4. If the IRS sends a second CDP Notice under section
6320 (other than a substitute CDP Notice) for a tax period and
with respect to an unpaid tax for which a section 6320 CDP Notice
was previously sent, is the taxpayer entitled to a section 6320
CDP hearing based on the second CDP Notice?
A-B4. No. The taxpayer is entitled to a CDP hearing under
section 6320 for each tax period only with respect to the first
(continued...)
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