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          related litigation in this Court, challenge the underlying tax              
          liability.  Secs. 6320(c), 6330(c)(2)(B); Lewis v. Commissioner,            
          128 T.C. __, __ (2007) (slip op. at 24); Sego v. Commissioner,              
          114 T.C. 604, 610-611 (2000); Goza v. Commissioner, 114 T.C. 176,           
          182-183 (2000); sec. 301.6320-1(e)(1), Proced. & Admin. Regs.               
               Thus, where a taxpayer has received a prior lien or levy               
          notice under section 6320 or section 6330 which could have been             
          appealed to respondent’s Appeals Office, relating to the same               
          year and the same underlying tax liability as is involved in a              
          subsequent lien or levy notice, the taxpayer is treated with                
          regard to the subsequent lien or levy notice as already having              
          had a prior opportunity to dispute the underlying tax liability.            
          Sec. 301.6320-1(e)(3), Q&A-E2, Q&A-E7, Proced. & Admin. Regs.               
               Section 301.6320-1(e)(3), Q&A-E2, Proced. & Admin. Regs.,              
          explains as follows:                                                        

               An opportunity to dispute a liability includes a prior                 
               opportunity for a conference with Appeals that was                     
               offered either before or after the assessment of the                   
               liability.                                                             

               After requesting and receiving a copy of respondent’s notice           
          of deficiency, at petitioner’s equivalent hearing with                      
          respondent’s Appeals Office relating to respondent’s June 17,               
          2002, second levy notice, petitioner discussed and disputed with            
          respondent’s Appeals Office her alleged discharge of indebtedness           








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