Lester Ronald Coleman - Page 3
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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
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Last modified: November 10, 2007