Jason Harrington - Page 7




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          pleadings.  Grant Creek Water Works, Ltd. v. Commissioner, 91               
          T.C. 322, 325 (1988); Casanova Co. v. Commissioner, 87 T.C. 214,            
          217 (1986).                                                                 
               Section 6320(a)(1) requires the Secretary to give persons              
          liable to pay taxes written notice of the filing of a tax lien.             
          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).                                                              










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