Orlando Bujosa - Page 5




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          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 he            







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