- 4 - subsequently made the determination that the proposed levy action was appropriate for the taxable years 1987 and 1988, and a Notice of Determination was issued. Discussion Before a levy may be made on any property or right to property, a taxpayer is entitled to notice of the Commissioner’s intent to levy and notice of the right to a fair hearing before an impartial officer of the Internal Revenue Service (IRS) Appeals Office. Secs. 6330(a) and (b), 6331(d). Taxpayers may raise challenges to “the appropriateness of collection actions” and may make “offers of collection alternatives, which may include the posting of a bond, the substitution of other assets, an installment agreement, or an offer-in-compromise.” Sec. 6330(c)(2)(A). The Appeals officer must consider those issues, verify that the requirements of applicable law and administrative procedures have been met, and consider “whether any proposed collection action balances the need for the efficient collection of taxes with the legitimate concern of the person [involved] that any collection action be no more intrusive than necessary.” Sec. 6330(c)(3)(C). After the IRS Appeals hearing process, section 6330 gives this Court jurisdiction to review the Appeals officer’s determination. In an appeal to this Court pursuant to section 6330(d), a taxpayer may raise in his petition any issues that hePage: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007