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          (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.                  







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