- 4 - (2000). Upon the Appeals Office’s issuance of a determination letter, the taxpayer who seeks judicial review may appeal to this Court within 30 days of the determination. Section 6320(c) requires that the administrative hearing be conducted pursuant to section 6330(c), (d) (other than paragraph (2)(b) thereof), and (e). In order to invoke judicial review of a section 6320 determination, a taxpayer must be the person liable for the tax under section 6321 and must have received from the IRS a valid notice of determination based on a section 6320 hearing. See Offiler v. Commissioner, 114 T.C. 492, 498 (2000); see also Rule 330(b). Regulations promulgated under section 6320 state that known nominees of, or persons holding property of, the taxpayer are not entitled to a collection due process or equivalent hearing. Sec. 301.6320-1(b)(2), Q&A-B5, Proced. & Admin. Regs. Individuals not entitled to a section 6320 review are entitled to other forms of review, including reconsideration by the IRS office collecting the tax, assistance from the National Taxpayer Advocate, or an administrative hearing before the Appeals Office under the Collection Appeals Program. Id. Any determination resulting from these reviews, however, is not subject to judicial review. Id. The taxpayer for whom a nominee, transferee, or alter ego is holding property is entitled to a hearing under section 6320. Sec. 301.6320-1(b)(3), Example (2), Proced. & Admin. Regs.Page: Previous 1 2 3 4 5 6 NextLast modified: March 27, 2008