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Due Process in IRS Collection Actions

This information is intended as technical information of use to consultants and individuals doing research. The new IRS Hotline for any Appeals tax matter is 1-877-457-5055, whenever you need assistance with an Appeals tax matter.
Section 6320 of the Internal Revenue Code provides that the IRS must notify in writing the taxpayer against whom a "Notice of Federal Tax Lien" has been filed. This notification may be given in person, left at the taxpayer's dwelling or usual place of business, or sent to the taxpayer by certified or registered mail not more than five business days after the day the NFTL was filed. The notification must state the amount of unpaid tax, the right to request a hearing during a 30-day period following the end of the five-day notification period, the administrative appeals available to the taxpayer with respect to such lien and procedures relating to such appeals, and the provisions and procedures relating to the release of liens. The taxpayer is entitled to one hearing per tax period before an Appeals officer who has had no prior involvement with respect to that tax period. (The taxpayer may waive the requirement that the Appeals officer had no prior involvement with respect to that tax period.) Hearings with respect to liens may be held in conjunction with hearings under section 6330, involving levies. The period of limitations on collection with respect to that tax period is suspended while the hearing and any appeal of it are pending. At the hearing, the Appeals officer is required to receive verification that all legal and administrative requirements for filing the lien have been met. The taxpayer is allowed to raise any relevant issue at the hearing. Issues eligible to be raised include (but are not limited to) challenges to the underlying liability as to existence or amount, appropriate spousal defenses, challenges to the appropriateness of collection actions, and collection alternatives, which could include the posting of a bond, substitution of other assets, an installment agreement or an offer-in-compromise. Taxpayers may not raise any issue that was raised and considered at a previous hearing under section 6330 or in any other administrative or judicial proceeding if that taxpayer has participated meaningfully in such prior hearing or proceeding. The taxpayer may appeal the determination of the Appeals officer in the Tax Court or a U.S. District Court within 30 days of the date of the determination.

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Brought to you by Alvin S. Brown, Esq., attorney at law, former Supervisory Manager and Tax Attorney-Advisor, Internal Revenue Service, Office of Chief Counsel, Internal Revenue Service.

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