Wendell Ray Holloway - Page 5




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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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