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Face-to-Face Meeting
Section 6320(a)(1) requires the Secretary to give persons
liable to pay taxes a written notice of the filing of an NFTL.
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 shall 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 is filed may raise any relevant issues relating to the
unpaid tax or the lien, including appropriate spousal defenses,
challenges to the appropriateness of collection actions, and
collection alternatives. Sec. 6330(c)(2)(A). The person may
challenge the existence or amount of the underlying tax, however,
only if he did not receive any statutory notice of deficiency for
the tax liability or did not otherwise have an opportunity to
dispute the tax liability. Sec. 6330(c)(2)(B).
In the instant case, the record indicates that the only
issues petitioner raised throughout the section 6320
administrative process and in his petition to this Court were
frivolous and/or tax protester type arguments. We do not address
petitioner's frivolous arguments with somber reasoning and
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Last modified: November 10, 2007