Rose Lynn Richmond - Page 9




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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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