- 5 - section 6015 claim, that he had not responded, and that he had admitted receiving the notices but ignored them because contesting them might affect his child custody battle. After discussing each of petitioner’s claims, the notice sustained the proposed levy action to collect the liabilities owed for 1999, 2000, and 2001. Discussion Petitioner requested and received a hearing under section 6330. Section 6330(c)(2) provides: SEC. 6330(c). Matters Considered at Hearing.–-In the case of any hearing conducted under this section-- * * * * * * * (2) Issues at hearing.-- (A) In general.–-The person may raise at the hearing any relevant issue relating to the unpaid tax or the proposed levy, including-- (i) appropriate spousal defenses; (ii) challenges to the appropriateness of collection actions; and (iii) offers of collection alternatives, which may include the posting of a bond, the substitution of other assets, an installment agreement, or an offer-in-compromise. (B) Underlying liability.–-The person may also raise at the hearing challenges to the existence or amount of the underlying tax liability for any tax period if the person did not receive any statutory notice of deficiency for such tax liability or did notPage: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007