Richard Allan and Corinne Lucille Balser - Page 7




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               If a section 6330 hearing is requested, the hearing is to be           
          conducted by the Appeals Office of the Internal Revenue Service             
          (IRS), and at the hearing, the Appeals officer conducting it must           
          verify that the requirements of any applicable law or                       
          administrative procedures have been met.  Sec. 6330(b)(1),                  
          (c)(1).  The person requesting the hearing may raise any relevant           
          issue with regard to the Commissioner’s intended collection                 
          activities, including spousal defenses, challenges to the                   
          appropriateness of the Commissioner’s intended collection action,           
          and alternative means of collection.  Sec. 6330(c); see Sego v.             
          Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner, 114           
          T.C. 176, 180 (2000).                                                       
               In making a determination, the Appeals officer is required             
          to take into consideration issues properly raised, the                      
          verification that the requirements of applicable law and                    
          administrative procedures have been met, and whether any proposed           
          collection action balances the need for efficient collection of             
          taxes with the legitimate concern of the person that any                    
          collection action be no more intrusive than necessary.  Sec.                
          6330(c)(3).  Within 30 days after the Appeals Office issues a               
          notice of determination, the person may appeal the determination            
          to the Tax Court, if the Court has jurisdiction over the                    
          underlying tax liability.  Sec. 6330(d)(1)(A).  The Court has               
          jurisdiction in this case.                                                  







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