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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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Last modified: May 25, 2011