- 6 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: November 10, 2007