- 5 - A section 6330 hearing will be conducted if the taxpayer submits a timely written request in response to the section 6330(a) notice. Sec. 6330(b) and (c). The taxpayer must request the section 6330 hearing within the 30-day period commencing on the day after the date of the section 6330(a) notice. Sec. 6330(a)(3)(B); sec. 301.6330-1(b)(1), Proced. & Admin. Regs. If a taxpayer makes a timely request for a section 6330 hearing, a hearing shall be held before an impartial officer or employee of the Appeals Office.5 Sec. 6330(b)(1), (3). Following a section 6330 hearing, an Appeals officer will issue a notice of determination indicating whether the proposed levy action may proceed.6 Sec. 301.6330-1(e)(3), Q&A-E8, Proced. & Admin. Regs. Under section 6330(d)(1), the taxpayer may petition this Court to 5 At the sec. 6330 hearing, a taxpayer may raise any relevant issue, including appropriate spousal defenses, challenges to the appropriateness of the collection action, and collection alternatives. Sec. 6330(c)(2)(A). Taxpayers are precluded from contesting the existence or amount of the underlying tax liability unless the taxpayer failed to receive a notice of deficiency for the tax in question or did not otherwise have an earlier opportunity to dispute the tax liability. Sec. 6330(c)(2)(B); see also Sego v. Commissioner, 114 T.C. 604, 609 (2000). 6 In making its determination, the Appeals Office is required to take into consideration: (1) The verification presented by the Secretary that the requirements of applicable law and administrative procedures have been met; (2) the relevant issues raised by the taxpayer; and (3) whether the proposed levy action appropriately balances the need for efficient collection of taxes with a taxpayer’s concerns regarding the intrusiveness of the proposed levy action. Sec. 6330(c)(3).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007