Dudley Joseph Callahan and Myrna Dupuy Callahan - Page 9




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               section, appeal such determination to the Tax Court                    
               (and the Tax Court shall have jurisdiction with respect                
               to such matter).                                                       
               The Staff of the Joint Committee on Taxation, General                  
          Explanation of Tax Legislation Enacted in the 109th Congress                
          (JCS-1-07), at 507 (J. Comm. Print 2007), explains the amendment            
          to section 6330(d)(1):  “The provision modifies the jurisdiction            
          of the Tax Court by providing that all appeals of collection due            
          process determinations are to be made to the United States Tax              
          Court.”  We, therefore, have jurisdiction to review a notice of             
          determination issued under section 6330 where the underlying tax            
          liability consists of frivolous return penalties.                           
          C.   Matters Considered at Hearing                                          
               Section 6330(c) prescribes the matters that a person may               
          raise at the hearing.  Section 6330(c)(2)(A) provides that a                
          person may raise collection issues such as spousal defenses, the            
          appropriateness of the Commissioner’s intended collection action,           
          and possible alternative means of collection.  See Montgomery v.            
          Commissioner, 122 T.C. 1, 5 (2004); Sego v. Commissioner, 114               
          T.C. 604, 609 (2000); Goza v. Commissioner, 114 T.C. 176, 181-183           
          (2000).  In addition, section 6330(c)(2)(B) establishes the                 
          circumstances under which a person may challenge the existence or           
          amount of the underlying tax liability.  Section 6330(c)(2)(B)              
          provides:                                                                   








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