Nance Eva Dehring - Page 6




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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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