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Appeals hearing. AO Cleveland reviewed petitioners’
administrative file and transcripts for the years in issue, and
she verified that the requirements of all applicable laws and
administrative procedures had been met.
On September 13, 2005, the Appeals Office issued to
petitioners a notice of determination for 1992, 1993, and 1996
sustaining as appropriate respondent’s proposed levy action. The
Appeals Office further determined that the levy action should
proceed because petitioners had not made any arrangements to pay
the taxes.
On October 20, 2005, petitioners filed with the Court a
petition for lien or levy action.
Discussion
Procedure Under Section 6330
Section 6331 authorizes the Secretary to levy upon property
and property rights of a taxpayer liable for taxes who fails to
pay those taxes within 10 days after notice and demand for
payment. Section 6331(d) provides that the levy authorized in
section 6331(a) may be made with respect to any “unpaid tax” only
after the Secretary has notified the person in writing of his
intention to make the levy and of the taxpayer’s right to a
section 6330 hearing at least 30 days before any levy action is
begun.
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