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provides:
(2). Issues at hearing.--
* * * * * * *
(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
otherwise have an opportunity to dispute such tax
liability.
Respondent has promulgated regulations regarding section
6330(c)(2)(B) pursuant to his authority under section 7805(a).
Section 301.6330-1(e), Proced. & Admin. Regs., provides in
pertinent part:
(e) Matters considered at CDP hearing.--(1) In
general. * * * The taxpayer also may raise challenges
to the existence or amount of the tax liability
specified on the CDP Notice for any tax period shown on
the CDP Notice if the taxpayer did not receive a
statutory notice of deficiency for that tax liability
or did not otherwise have an opportunity to dispute
that tax liability. * * *
Section 301.6330-1(e)(3), Q&A-E2, Proced. & Admin. Regs.,
provides in pertinent part:
(3) Questions and answers. The questions and
answers illustrate the provisions of this paragraph (e)
as follows:
* * * * * * *
Q-E2. When is a taxpayer entitled to challenge
the existence or amount of the tax liability specified
in the CDP Notice?
A-E2. A taxpayer is entitled to challenge the
existence or amount of the tax liability specified in
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Last modified: November 10, 2007