Charles Michael Snyder - Page 5

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          applicable law or administrative procedure had been met, and that           
          the levy action balanced the need for the efficient collection of           
          tax with the concern that any collection action be no more                  
          intrusive than necessary.                                                   
               Section 6331(a) authorizes the Secretary to levy upon                  
          property and property rights of a taxpayer liable for tax who               
          fails to pay the tax within 10 days after the notice and demand             
          for payment is made.  Section 6331(d) provides that the levy                
          authorized in section 6331(a) may be made with respect to unpaid            
          tax only if the Secretary has given written notice to the                   
          taxpayer 30 days before the levy.  Section 6330(a) requires the             
          Secretary to send a written notice to the taxpayer of the amount            
          of the unpaid tax and of the taxpayer’s right to a section 6330             
          hearing at least 30 days before the levy is made.                           
               If a section 6330 hearing is requested, the hearing is to be           
          conducted by the Office of Appeals, and, at the hearing, the                
          Appeals officer conducting it must verify that the requirements             
          of any applicable law or administrative procedure have been met.            
          Sec. 6330(b)(1) and (c)(2).  The taxpayer may raise at the                  
          hearing “any relevant issue relating to the unpaid tax or the               
          proposed levy”.  Sec. 6330(c)(2)(A).  The taxpayer may also raise           
          challenges to the existence or amount of the underlying tax                 
          liability at a hearing if the taxpayer did not receive a                    

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Last modified: May 25, 2011