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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 not
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