Jonita Conner - Page 5

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          433-F, Collection Information Statement.2  Respondent had not               
          previously received these documents from petitioner.                        
                                     Discussion                                       
               Section 6331(a) 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 a notice and demand           
          for payment is made.  Section 6331(d) provides that the levy may            
          be made only if the Secretary has given written notice to the               
          taxpayer 30 days before the levy.  Section 6330(a) requires the             
          Secretary to send a written notice to the taxpayer of the amount            
          of the unpaid tax and of the taxpayer’s right to a section 6330             
          hearing at least 30 days before the levy is begun.                          
               If a section 6330 hearing is requested, the hearing is to be           
          conducted by the Office of Appeals, and the Appeals officer                 
          conducting it must verify that the requirements of any applicable           
          law or administrative procedure have been met.  Sec. 6330(b)(1),            
          (c)(1).  The taxpayer may raise at the hearing any relevant issue           
          relating to the unpaid tax or the proposed levy.  Sec.                      


               2 Both the Form 433-A and the Form 433-F require the                   
          taxpayer to provide financial information.  The Form 433-F is a             
          1-page document that asks the taxpayer to list items such as                
          monthly income and expenses.  The Form 433-A, in contrast, is a             
          6-page document that requires the taxpayer, inter alia, to list             
          income and expenses for a 3-month period; attach copies of                  
          documents such as pay stubs, bank statements, and proof of                  
          current expenses; and indicate whether the taxpayer has                     
          transferred assets out of his or her name for less than actual              
          value.                                                                      





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