Claude E. and Dana L. Salazar - Page 8

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          underlying tax liability.  Sec. 6330(c)(2)(B).  After the                   
          hearing, the Appeals officer who presided over the hearing is               
          required to issue a notice of determination that must set forth             
          the officer’s findings and decisions, including the following:              
               [The Notice of Determination] will state whether the                   
               IRS met the requirements of any applicable law or                      
               administrative procedure; it will resolve any issues                   
               appropriately raised by the taxpayer relating to the                   
               unpaid tax; it will include a decision on any                          
               appropriate spousal defenses raised by the taxpayer; it                
               will include a decision on any challenges made by the                  
               taxpayer to the appropriateness of the collection                      
               action; it will respond to any offers by the taxpayer                  
               for collection alternatives; and it will address                       
               whether the proposed collection action represents a                    
               balance between the need for the efficient collection                  
               of taxes and the legitimate concern of the taxpayer                    
               that any collection action be no more intrusive than                   
               necessary.  The Notice of Determination will also set                  
               forth any agreements that Appeals reached with the                     
               taxpayer, any relief given the taxpayer, and any                       
               actions the taxpayer or the IRS are required to take.                  
               Lastly, the Notice of Determination will advise the                    
               taxpayer of the taxpayer’s right to seek judicial                      
               review within 30 days of the date of the Notice of                     
               Determination.                                                         
          Sec. 301.6330-1(e)(3), Q&A-E8, Proced. & Admin. Regs.  In                   
          deciding whether we have jurisdiction over a proceeding filed               
          pursuant to section 6330, we have held that a notice of                     
          determination includes a “written notice that embodies a                    
          determination to proceed with the collection of the taxes in                
          issue.”  Sapp v. Commissioner, T.C. Memo. 2003-207 (citing                  
          Lunsford v. Commissioner, 117 T.C. 159, 164 (2001)); see also               
          Craig v. Commissioner, 119 T.C. 252, 259 (2002).                            







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