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procedure have been met. Sec. 6330(c)(1). Second, the taxpayer
may raise any issue relevant to the unpaid tax or proposed
collection action at the hearing, including spousal defenses,
challenges to the appropriateness of the collection action, and
offers of collection alternatives. Sec. 6330(c)(2)(A).
Additionally, the taxpayer may contest the existence and amount
of the underlying tax liability, but only if he or she did not
receive a notice of deficiency or otherwise have an opportunity
to dispute the tax liability. Sec. 6330(c)(2)(B). Section
6330(c)(4) provides in pertinent part that a taxpayer may not
raise an issue at the hearing if the issue was raised and
considered at a previous administrative or judicial proceeding
and the taxpayer participated meaningfully in such proceeding.4
4 Sec. 6330(c)(4) provides:
SEC. 6330(c). Matters Considered at Hearing.--In the
case of any hearing conducted under this section–-
* * * * * * *
(4) Certain issues precluded.--An issue may not be
raised at the hearing if--
(A) the issue was raised and considered at a
previous hearing under section 6320 or in any
other previous administrative or judicial
proceeding; and
(B) the person seeking to raise the issue
participated meaningfully in such hearing or
proceeding.
This paragraph shall not apply to any issue with
(continued...)
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Last modified: March 27, 2008