- 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. Discussion 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 collectionPage: Previous 1 2 3 4 5 6 NextLast modified: November 10, 2007