Lester Ronald Coleman - Page 3

                                        - 3 -                                         
          1994 and 1995.  On the basis of the lien notice, petitioner                 
          timely sent respondent a Form 12153, Request for a Collection Due           
          Process Hearing.  At the hearing, petitioner disputed only his              
          tax liabilities for the taxable years 1994 and 1995.  Petitioner            
          did not offer any collection alternatives at the hearing.                   
               On December 16, 2005, respondent sent petitioner a Notice of           
          Determination Concerning Collection Action(s) under section 6320            
          and/or 6330.  Petitioner timely petitioned the Court.                       
               Section 6320(a)(1) requires the Secretary to give persons              
          liable to pay taxes written notice of the filing of a tax lien.             
          Section 6320(a)(3)(B) and (b)(1) provides that the notice shall             
          inform such persons of the right to request a hearing in                    
          respondent’s Appeals Office.                                                
               Section 6320(c) provides that an Appeals Office hearing                
          generally should be conducted consistently with the procedures              
          set forth in section 6330(c), (d), and (e).  The Appeals officer            
          must verify at the hearing that the applicable laws and                     
          administrative procedures have been followed.  Sec. 6330(c)(1).             
          At the hearing, the person against whom the lien or levy is made            
          may raise any relevant issues relating to the unpaid tax or lien,           
          including appropriate spousal defenses, challenges to the                   
          appropriateness of collection actions, and collection                       

Page:  Previous  1  2  3  4  5  6  Next 

Last modified: November 10, 2007