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attend the scheduled conference. Petitioner did send to Appeals
a letter dated July 14, 2005, in which she apologized for having
“missed our appointment for today.”
Having received no information from petitioner, respondent
issued the Notice of Ddetermination on October 13, 2005.
OPINION
Section 6330
Section 6330 generally provides that the Commissioner cannot
proceed with collection by way of a levy until the taxpayer has
been given notice and the opportunity for an administrative
review of the matter (in the form of an Appeals Office hearing),
and, if dissatisfied, the person may obtain judicial review of
the administrative determination. See Davis v. Commissioner, 115
T.C. 35, 37 (2000); Goza v. Commissioner, 114 T.C. 176, 179
(2000). The taxpayer requesting the hearing may raise any
relevant issue with regard to the Commissioner’s intended
collection activities, including spousal defenses, challenges to
appropriateness of the collection action, and offers of
collection alternatives. Sec. 6330(c); see Sego v. Commissioner,
114 T.C. 604, 609 (2000); Goza v. Commissioner, supra at 180.
Where the validity of the tax liability is not properly part
of the appeal, the taxpayer may challenge the determination of
the Appeals officer for abuse of discretion. Sego v.
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