Ralph Tashjian - Page 10

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          taxpayer’s property until the taxpayer has been given notice of             
          and the opportunity for an administrative review of the proposed            
          levy (in the form of an IRS Office of Appeals hearing).  Section            
          6330(c)(1) provides that the Appeals officer shall obtain                   
          verification that the requirements of any applicable law or                 
          administrative procedure have been met.  Section 6330(c)(2)(A)              
          provides that the taxpayer may raise "any relevant issue relating           
          to the unpaid tax” including spousal defenses, challenges to the            
          appropriateness of collection actions, and alternatives to                  
          collection.  The taxpayer may also raise challenges to the                  
          existence or amount of the underlying tax liability if he or she            
          did not receive a statutory notice of deficiency with respect to            
          the underlying tax liability or did not otherwise have an                   
          opportunity to dispute that liability.  Sec. 6330(c)(2)(B).                 
               Section 6330(c)(3) provides that the determination of the              
          Appeals officer shall take into consideration the verification              
          under section 6330(c)(1), the issues raised by the taxpayer, and            
          whether the proposed collection action balances the need for the            
          efficient collection of taxes with the legitimate concern of the            
          taxpayer that any collection action be no more intrusive than               
          necessary.  If the taxpayer is dissatisfied with the                        
          determination made after the hearing, judicial review of the                
          determination, such as that sought in this case, is available.              
          See generally Goza v. Commissioner, 114 T.C. 176, 179-181 (2000).           

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