Peter D. Dahlin Attorney at Law, P.S. - Page 7




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          did not otherwise have an opportunity to dispute the tax                    
          liability.  Sec. 6330(c)(2)(B).                                             
               In rendering a determination, the Appeals officer must                 
          verify that the requirements of any applicable law and                      
          administrative procedure have been met.  Also, the Appeals                  
          officer must consider and weigh relevant issues relating to the             
          unpaid tax or proposed levy, and “whether any proposed collection           
          action balances the need for the efficient collection of taxes              
          with the legitimate concern of the person that any collection               
          action be no more intrusive than necessary.”  Sec. 6330(c)(3)(B)            
          and (C).                                                                    
               The taxpayer is entitled to appeal the determination of the            
          Appeals Office if it was made on or before October 16, 2006, to             
          the Tax Court or a U.S. District Court, depending on the type of            
          tax at issue.  Sec. 6330(d)(1).6  Where the validity of the                 
          underlying tax liability is properly at issue, the Court will               
          review the matter de novo.  Sego v. Commissioner, 114 T.C. 604,             
          610 (2000); Goza v. Commissioner, 114 T.C. 176, 181-182 (2000).             
          The Court reviews any other administrative determination                    
          regarding the proposed levy action for an abuse of discretion.              
          Sego v. Commissioner, supra at 610; Goza v. Commissioner, supra             
          at 182.                                                                     


               6Determinations made after Oct. 16, 2006, are appealable               
          only to the Tax Court.  See Pension Protection Act of 2006, Pub.            
          L. 109-280, sec. 855, 120 Stat. 1019.                                       





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