Notice & Opportunity for Hearing before Levy

DEPARTMENT OF THE TREASURY
Internal Revenue Service 26 CFR Part 301 [TD 8809] RIN 1545-AW76

TITLE: Notice and Opportunity for Hearing before Levy

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Temporary regulations.

SUMMARY: This document contains temporary regulations relating to
the provision of notice to taxpayers of a right to a hearing before
levy. The regulations implement certain changes made by section 3401
of the Internal Revenue Service Restructuring and Reform Act of
1998. They affect taxpayers against whose property the IRS intends
to levy. The text of these regulations also serves as the text of
the proposed regulations set forth in the notice of proposed
rulemaking on this subject in the Proposed Rules section of this
issue of the Federal Register.

DATES: This regulation is effective January 19, 1999.

FOR FURTHER INFORMATION CONTACT: Jerome D. Sekula (202) 622-3610
(not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

This document contains amendments to the Procedure and
Administration Regulations (26 CFR part 301) that reflect the
addition of section 6330 to the Internal Revenue Code made by
section 3401 of the Internal Revenue Service Restructuring and
Reform Act of 1998 (RRA).

Prior to January 1, 1983, the IRS was only required to notify a
taxpayer of its intention to levy in the case of proposed levies on
salary or wages. Section 6331(d) was amended as a part of the Tax
Equity and Fiscal Responsibility Act of 1982 (TEFRA). The TEFRA
amendment required the IRS to give a taxpayer a notice of its
intention to levy, in non-jeopardy situations, before any levy was
made upon the salary, wages, or other property of the taxpayer. The
legislative history of the TEFRA amendment recognized that, although
a single notice of intent to levy relating to all property would be
sufficient, the IRS was not precluded from sending multiple notices
of intention to levy.

Under section 6331(a), the IRS may levy upon a taxpayer's property
and rights to property if a taxpayer fails to pay a tax liability.
Exemptions from levy are provided for certain property under section
6334(a). The first step toward levy generally occurs when the IRS
provides a taxpayer with a written notice and demand for payment.
Under section 6303, a notice and demand is a notice which states
that the tax has been assessed and demands that payment be made. If,
in non-jeopardy situations, the taxpayer fails to pay the tax within
10 days after notice and demand, the IRS may seize a taxpayer's
property or rights to property 30 days after sending the taxpayer a
notice required under section 6331(d), called a Notice of Intent to
Levy. Although the notice and demand and the Notice of Intent to
Levy may be combined and sent at the same time under Treas. Reg.

�301.6331-2(a)(1), under current practice these two notices are
usually sent separately. Generally, the notice and demand is sent
first and, as the second step in the levy process, the Notice of
Intent to Levy is sent at a later time. The IRS is permitted to
proceed with immediate seizure of a taxpayer's property or rights to
property without regard to the 10-day waiting period if it
determines that the collection of the tax is in jeopardy.

Under section 6331(d), the Notice of Intent to Levy must contain a
brief statement, in simple, nontechnical terms, that sets forth (A)
the statutory provisions relating to the levy and sale of property,
(B) the procedures applicable to the levy and sale of property, (C)
the administrative appeals available to the taxpayer with respect to
levy and sale and the procedures relating to those appeals, (D) the
alternatives available to taxpayers that could prevent levy on the
property (including installment agreements), (E) the statutory
provisions relating to redemption of property and the release of
liens on property, and (F) the procedures applicable to the
redemption of property and the release of a lien on property. The
Notice of Intent to Levy must be given in person, left at the
taxpayer's dwelling or usual place of business, or sent by
registered or certified mail to the taxpayer's last known address.

Prior to January 19, 1999, the IRS generally complied with the
requirements of section 6331(d) by giving the taxpayer a Final
Notice of Intent to Levy, and enclosing certain IRS publications
which explain the law, IRS levy and redemption procedures,
administrative appeal processes and procedures, and various
collection alternatives.

Section 6330 provides that, except when the Secretary finds that
collection of the tax is in jeopardy or a levy is issued to collect
State tax refunds due to the taxpayer, no levy may be made on or
after January 19, 1999, unless the Secretary notifies the taxpayer
in writing of a right to a hearing before the IRS Office of Appeals
(Appeals) with respect to the unpaid tax for the tax period. When
the Secretary has found jeopardy exists and in cases where a levy is
made on a State tax refund, the taxpayer will be given notice of a
right to, and the opportunity for, a hearing within a reasonable
time after the levy action has actually occurred.

Except when it determines that collection of the tax is in jeopardy
or it levies on State tax refunds, the IRS is prohibited from
levying upon the taxpayer's property or rights to property until 30
days after providing the taxpayer with the notice of a right to a
hearing before Appeals. If the taxpayer requests such a hearing, the
IRS is, in the absence of jeopardy, prohibited from levying upon the
taxpayer's property until the determination reached by Appeals
becomes final.

In order to implement the provisions of section 6330, the IRS is
going to modify the procedures it follows leading up to the issuance
of a levy. In the absence of a determination that collection of the
taxes is in jeopardy, the IRS will continue to provide a number of
notices to a taxpayer before levying upon the taxpayer's property.

Under the procedures the IRS is adopting to implement section 6330,
the levy process will continue to begin with issuance to the
taxpayer of a written notice and demand for payment. Absent a
jeopardy determination, a taxpayer who fails to pay the tax
specified in the notice and demand within 10 days after notice and
demand may, in addition to other notices such as the annual notice
of tax delinquency required under section 7524, be sent an Urgent
Notice. The Urgent Notice will inform the taxpayer that the IRS may
levy upon a taxpayer's State tax refund after 30 days from the date
of that notice. This Urgent Notice will include all information
required under section 6331(d) and will constitute the notice
required under that section.

Accordingly, the Urgent Notice will also begin the ten-day period
leading to an increase in the failure to pay penalty prescribed by
section 6651(d).

These temporary regulations implement the provisions of section 6330
and thus set forth the procedures the IRS will follow regarding
notice to taxpayers of a right to a hearing before Appeals, the
procedures that will be followed at those hearings, judicial review
of the determinations reached at the hearings, and the suspensions
of various periods of limitation as a result of a timely request for
a hearing. The legislative history accompanying RRA also explains
that Congress intended the IRS to grant an equivalent hearing to
taxpayers who do not request a hearing under section 6330 within the
30-day period following the date of notification. H. Conf. Rep. No.
599, 105th Cong., 2d Sess. 266 (1998). These temporary regulations
set forth the procedural requirements and rules that will govern the
conduct of such an equivalent hearing.

Explanation of Provisions

The temporary regulations provide that, except in the case of
jeopardy levies or levies on State tax refunds, the IRS must notify
the taxpayer of its intention to levy prior to issuing a levy. The
notification under section 6330 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, return receipt requested,
to the taxpayer's last known address at least 30 days prior to the
first proposed levy action with respect to the amount of the unpaid
tax for the tax period.

The temporary regulations also provide procedures to be followed in
the event the notification, if mailed, is not mailed to the
taxpayer's last known address. In jeopardy situations and in cases
where a levy is made on a State tax refund, notification to the
taxpayer of a right to a hearing is not required to be given until
the levy action has actually occurred. The temporary regulations set
forth the procedures to be followed for making the required pre-levy
and post-levy notifications.

Both such notifications must (A) set forth the amount of unpaid tax,
(B) notify the taxpayer of the right to request a hearing within the
30-day period that commences the day after the date of notification,
(C) indicate, as appropriate, that the IRS has levied or plans to
levy, and (D) describe the rights of the taxpayer with respect to
such action, including a brief statement which explains (1) the
provisions of the Internal Revenue Code (Code) relating to levy and
sale of property, (2) the procedures applicable to the levy and sale
of property under the Code, (3) the administrative appeals available
to the taxpayer with respect to such levy and sale and the
procedures relating to such appeals, (4) the alternatives available
to taxpayers which might forestall future levies on property
(including installment agreements under section 6159), and (5) the
provisions of the Code and procedures relating to redemption of
property and release of liens on property.

Unless the taxpayer withdraws the request that Appeals conduct a
hearing when the taxpayer has made a timely request for a collection
due process hearing, Appeals will hold one section 6330 collection
due process hearing (CDP hearing) with respect to the tax and tax
period or periods specified in the collection due process notice
(CDP Notice). The taxpayer is entitled to have a hearing conducted
by an Appeals officer who has had no prior involvement with the
unpaid tax that is the subject of the hearing. This requirement,
however, can be waived by the taxpayer in writing. A taxpayer may
seek judicial review of an Appeals determination issued with respect
to a CDP hearing.

Hearings with respect to levies may be held in conjunction with
hearings under section 6320, involving liens.

If the taxpayer timely requests a CDP hearing, the periods of
limitation relating to collection after assessment, relating to
criminal prosecution, and relating to suits are suspended until the
suspension ends as a result of the taxpayer's withdrawal of the
request for a CDP hearing or until the determination reached at the
CDP hearing becomes final by the expiration of the time for seeking
review or reconsideration before the appropriate court. Prior to
issuance of the Appeals determination, the Appeals officer must
verify that all legal and administrative requirements pertaining to
the proposed levy have been met. The temporary regulations further
discuss the types of issues that may or may not be raised at the CDP
hearing. The types of issues that may be raised at the hearing
include appropriate spousal defenses; challenges to the
appropriateness of collection actions; collection alternatives; and
challenges to the existence or amount of the liability specified in
the CDP Notice. An issue may not be raised at the CDP hearing if the
issue was raised and considered at a previous hearing under section
6320 or any other previous administrative or judicial proceeding in
which the taxpayer meaningfully participated.

Challenges to the existence or amount of the tax liability specified
in the CDP Notice may be raised only if the taxpayer did not receive
a statutory notice of deficiency for such liability or did not
otherwise have an opportunity to dispute such liability.

Following the CDP hearing, the Appeals officer will issue a Notice
of Determination, which can be appealed to the United States Tax
Court or a district court of the United States by filing an
appropriate pleading with the court that has jurisdiction over the
type of tax involved within 30 days of the date of the
determination. The temporary regulations discuss the content of the
Notice of Determination and the rules for obtaining judicial review.
The temporary regulations also provide guidance as to the extent to
which the Appeals officer will retain jurisdiction with respect to
the determination.

Lastly, the temporary regulations provides rules and procedures with
respect to the administrative hearing (referred to as an A
equivalent hearing @ ) the IRS will provide to taxpayers who do not
timely request a hearing under section 6330.

Special Analyses

It has been determined that this Treasury decision is not a
significant regulatory action as defined in Executive Order 12866.
Therefore, a regulatory assessment is not required. It has also been
determined that section 553 (b) of the Administrative Procedure Act
(5 U.S.C. chapter 5) does not apply to these regulations. For the
applicability of the Regulatory Flexibility Act (5 U.S.C. chapter 6)
refer to the Special Anayses section of the preamble to the cross
reference notice of proposed rulemaking published in the Proposed
Rules section of this issue of the Federal Register. Pursuant to
section 7805 (f) of the Internal Revenue Code, this temporary
regulation will be submitted to the Chief Counsel for Advocacy of
the Small Business Administration for comment on its impact on small
business.

Drafting Information

The principal author of this regulation is Jerome D. Sekula, Office
of Assistant Chief Counsel (General Litigation). However, other
personnel from the IRS and Treasury Department participated in its
development.

List of Subjects in 26 CFR Part 301

Employment taxes, Estate taxes, Excise taxes, Gift taxes, Income
taxes, Penalties, Reporting and recordkeeping requirements.

Adoption of Amendments to the Regulations Accordingly, 26 CFR part
301 is amended as follows:

PART 301--PROCEDURE AND ADMINISTRATION

Paragraph 1. The authority citation for part 301 continues to read
in part as follows:

Authority: 26 U.S.C. 7805 * * *

Par. 2. Section 301.6330-1T is added under the undesignated
centerheading A Seizure of Property for Collection of Taxes @ to
read as follows:

�301.6330-1T Notice and opportunity for hearing prior to levy
(temporary).

(a) Notification--(1) In general. Except as specified in paragraph
(a)(2) of this section, the district directors, directors of service
centers, and the Assistant Commissioner (International), or their
successors, are required to provide persons upon whose property or
rights to property the IRS intends to levy on or after January 19,
1999, notice of that intention and to give them the right to, and
the opportunity for, a pre-levy Collection Due Process hearing (CDP
hearing) with the Internal Revenue Service Office of Appeals
(Appeals). This Collection Due Process Hearing Notice (CDP Notice)
must be given in person, left at the dwelling or usual place of
business of such person, or sent by certified or registered mail,
return receipt requested, to such person's last known address.

(2) Exceptions--(i) State tax refunds. Section 6330 does not require
the IRS to provide the taxpayer a notification of the taxpayer's
right to a CDP hearing prior to issuing a levy to collect State tax
refunds owing to the taxpayer. However, the district director, the
service center director, and the Assistant Commissioner
(International), or their successors, are required to give notice of
the right to, and the opportunity for, a CDP hearing with Appeals
with respect to the tax liability for the tax period for which the
levy on the State tax refund was made on or after January 19, 1999,
within a reasonable time after the levy has occurred. The
notification required to be given following a levy on a State tax
refund is referred to as a post-levy CDP Notice.

(ii) Jeopardy. Section 6330 does not require the IRS to provide the
taxpayer a notification of the taxpayer's right to a CDP hearing
prior to levy when there has been a determination that collection of
the tax is in jeopardy. However, the district director, the service
center director, and the Assistant Commissioner (International), or
their successors, are required to provide notice of the right to,
and the opportunity for, a CDP hearing with Appeals to the taxpayer
with respect to any such levy issued on or after January 19, 1999,
within a reasonable time after the levy has occurred. The
notification required to be given following a jeopardy levy is also
referred to as post-levy CDP Notice.

(3) Questions and answers. The questions and answers illustrate the
provisions of this paragraph (a) as follows:

Q-A1. Who is the A person @ to be notified under section 6330?

A-A1. Under section 6330(a)(1), a pre-levy or post-levy CDP Notice
is only required to be given to the person whose property or right
to property is intended to be levied upon, or, in the case of a levy
made on a State tax refund or in the case of a jeopardy levy, the
person whose property or right to property was levied upon. The
person described in section 6330(a)(1) is the same person described
in section 6331(a). Pursuant to section 6331(a), notice is to be
given to the person liable to pay the tax due after notice and
demand who refuses or neglects to pay (hereinafter referred to as
the taxpayer).

Q-A2. Will the IRS notify a known nominee of, a person holding
property of, or a person who holds property subject to a lien with
respect to the taxpayer of its intention to issue a levy?

A-A2. No. Such a person is not the person described in section
6331(a), but such persons have other remedies. See A-B5 of this
paragraph (a)(3).

Q-A3. Will the IRS give notification for each tax and tax period it
intends to include or has included in a levy issued on or after
January 19, 1999?

A-A3. Yes. The notification of intent to levy or of the issuance of
a jeopardy or State tax refund levy will specify each tax and tax
period that will be or was included in the levy.

Q-A4. Will the IRS give notification to a taxpayer with respect to
levies for a tax and tax period issued on or after January 19, 1999,
even though the IRS had issued a levy prior to January 19, 1999,
with respect to the same tax and tax period?

A-A4. Yes. The IRS will provide appropriate pre-levy or post-levy
notification to a taxpayer regarding the first levy it intends to
issue or has issued on or after January 19, 1999, with respect to a
tax and tax period, even though it had issued a levy with respect to
that same tax and tax period prior to January 19, 1999.

Q-A5. When will the IRS provide this notice?

A-A5. Pursuant to section 6330(a)(1), beginning January 19, 1999,
the IRS will give a pre-levy CDP Notice to the taxpayer of its
intent to levy on property or rights to property, other than State
tax refunds and in jeopardy levy situations, at least 30 days prior
to the first such levy with respect to a tax and tax period. If the
taxpayer has not received a pre-levy CDP Notice and the IRS levies
on a State tax refund or issues a jeopardy levy on or after January
19, 1999, the IRS will provide a post-levy CDP Notice to the
taxpayer within a reasonable time after that levy.

Q-A6. What must the pre-levy CDP Notice include?

A-A6. Pursuant to section 6330(a)(3), the notification must include,
in simple and nontechnical terms:

(i) The amount of the unpaid tax.

(ii) Notification of the right to a hearing.

(iii) A statement that the IRS intends to levy.

(iv) The taxpayer's rights with respect to the levy action,
including a brief statement that sets forth--

(A) The statutory provisions relating to the levy and sale of
property;

(B) The procedures applicable to the levy and sale of property;

(C) The administrative appeals available to the taxpayer with
respect to levy and sale and the procedures relating to those
appeals;

(D) The alternatives available to taxpayers that could prevent levy
on the property (including installment agreements);

(E) The statutory provisions relating to redemption of property and
the release of liens on property; and

(F) The procedures applicable to the redemption of property and the
release of liens on property.

Q-A7. What must the post-levy CDP Notice include?

A-A7. Pursuant to section 6330(a)(3), the notification must include,
in simple and nontechnical terms:

(i) The amount of the unpaid tax.

(ii) Notification of the right to a hearing.

(iii) A statement that the IRS has levied upon the taxpayer's State
tax refund or has made a jeopardy levy on property or rights to
property of the taxpayer, as appropriate.

(iv) The taxpayer's rights with respect to the levy action,
including a brief statement that sets forth--

(A) The statutory provisions relating to the levy and sale of
property;

(B) The procedures applicable to the levy and sale of property;

(C) The administrative appeals available to the taxpayer with
respect to levy and sale and the procedures relating to those
appeals;

(D) The alternatives available to taxpayers that could prevent any
further levies on the taxpayer's property (including installment
agreements);

(E) The statutory provisions relating to redemption of property and
the release of liens on property; and

(F) The procedures applicable to the redemption of property and the
release of liens on property.

Q-A8. How will this pre-levy or post-levy notification be
accomplished?

A-A8. (i) The IRS will notify the taxpayer by means of a pre-levy
CDP Notice or a post-levy CDP Notice, as appropriate.

The additional information IRS is required to provide, together with
Form 12153, Request for a Collection Due Process Hearing, will be
included with that Notice. The IRS may effect delivery of a pre-levy
CDP Notice (and accompanying materials) in one of three ways:

(A) By delivering the notice personally to the taxpayer.

(B) By leaving the notice at the taxpayer's dwelling or usual place
of business.

(C) By mailing the notice to the taxpayer at the taxpayer's last
known address by certified or registered mail, return receipt
requested.

(ii) The IRS may effect delivery of a post-levy CDP Notice (and
accompanying materials) in one of three ways:

(A) By delivering the notice personally to the taxpayer.

(B) By leaving the notice at the taxpayer's dwelling or usual place
of business.

(C) By mailing the notice to the taxpayer at the taxpayer's last
known address by certified or registered mail.

Q-A9. What are the consequences if the taxpayer does not receive or
accept the notification which was properly left at the taxpayer's
dwelling or usual place of business, or properly sent by certified
or registered mail, return receipt requested, to the taxpayer's last
known address?

A-A9. Notification properly sent to the taxpayer's last known
address or left at the taxpayer's dwelling or usual place of
business is sufficient to start the 30-day period within which the
taxpayer may request a CDP hearing. Actual receipt is not a
prerequisite to the validity of the notice.

Q-A10. What if the taxpayer does not receive the CDP Notice because
the IRS did not send that notice by certified or registered mail to
the taxpayer's last known address, or failed to leave it at the
dwelling or usual place of business of the taxpayer, and the
taxpayer fails to request a CDP hearing with Appeals within the 30-
day period commencing the day after the date of the CDP Notice?

A-A10. When the IRS determines that it failed properly to provide a
taxpayer with a CDP Notice, it will promptly provide the taxpayer
with a substitute CDP Notice and provide the taxpayer with an
opportunity to request a CDP hearing.

(4) Examples. The following examples illustrate the principles of
this paragraph (a):

Example 1. Prior to January 19, 1999, the IRS issues a continuous
levy on a taxpayer's wages and a levy on that taxpayer's fixed right
to future payments. The IRS is not required to release either levy
on or after January 19, 1999, until the requirements of section
6343(a)(1) are met. The taxpayer is not entitled to a CDP Notice or
a CDP hearing under section 6330 with respect to either levy because
both levy actions were initiated prior to January 19, 1999.

Example 2. The same facts as in Example 1, except the IRS intends to
levy upon a taxpayer's bank account on or after January 19, 1999.
The taxpayer is entitled to a pre-levy CDP Notice with respect to
this proposed new levy.

(b) Entitlement to a CDP hearing--(1) In general. A taxpayer is
entitled to one CDP hearing with respect to the tax and tax period
covered by the pre-levy or post-levy CDP Notice provided the
taxpayer. The taxpayer must request such a hearing within the 30-day
period commencing on the day after the date of the CDP Notice.

(2) Questions and answers. The questions and answers illustrate the
provisions of this paragraph (b) as follows:

Q-B1. Is the taxpayer entitled to a CDP hearing where a levy for
State tax refunds is served on or after January 19, 1999, even
though the IRS had previously served other levies prior to January
19, 1999, seeking to collect the taxes owed for the same period?

A-B1. Yes. The taxpayer is entitled to a CDP hearing under section
6330 for the tax and tax period set forth in such a levy issued on
or after January 19, 1999.

Q-B2. Is the taxpayer entitled to a CDP hearing when the IRS, more
than 30 days after issuance of a CDP Notice with respect to a tax
period, provides subsequent notice to that taxpayer that it intends
to levy on property or rights to property of the taxpayer for the
same tax and tax period shown on the CDP Notice?

A-B2. No. Under section 6330, only the first pre-levy or post-levy
Notice with respect to liabilities for a tax and tax period
constitutes a CDP Notice. If the taxpayer does not timely request a
CDP hearing with Appeals following that first notification, the
taxpayer foregoes the right to a CDP hearing with Appeals and
judicial review of Appeals's determination with respect to
collection activity relating to that tax and tax period. The IRS
generally provides additional notices or reminders (reminder
notifications) to the taxpayer of its intent to levy when no
collection action has occurred within 180 days of a proposed levy.
Under such circumstances a taxpayer, however, may request an
equivalent hearing as described in paragraph (i) of this section.

Q-B3. When the IRS provides a taxpayer with a substitute CDP Notice
and the taxpayer timely requests a CDP hearing, is the taxpayer
entitled to a CDP Hearing before Appeals?

A-B3. Yes. Unless the taxpayer provides the IRS a written withdrawal
of the request that Appeals conduct a CDP hearing, the taxpayer is
entitled to a CDP hearing before Appeals. Following the hearing,
Appeals will issue a Notice of Determination, and the taxpayer is
entitled to seek judicial review of that Notice of Determination.

Q-B4. If the IRS sends a second CDP Notice under section 6330 (other
than a substitute CDP Notice) for a tax period and with respect to
an amount of unpaid tax for which a section 6330 CDP Notice was
previously sent, is the taxpayer entitled to a second section 6330
CDP hearing?

A-B4. No. The taxpayer is entitled to only one CDP hearing under
section 6330 with respect to the tax and tax period. The taxpayer
must request the CDP hearing within 30 days of the date of the first
CDP Notice provided for that tax and tax period.

Q-B5. Will the IRS give pre-levy or post-levy CDP Notices to known
nominees of, persons holding property of, or persons holding
property subject to a lien with respect to the taxpayer?

A-B5. No. Such person is not the person described in section 6331(a)
and is, therefore, not entitled to a CDP hearing or an equivalent
hearing (as discussed in paragraph (i) of this section). Such
person, however, may seek reconsideration by the IRS office
collecting the tax, assistance from the National Taxpayer Advocate,
or an administrative hearing before Appeals under its Collection
Appeals Program. However, any such administrative hearing would not
be a CDP hearing under section 6330 and any determination or
decision resulting from the hearing would not be subject to judicial
review.

(c) Requesting a CDP hearing--(1) In general. Where a taxpayer is
entitled to a CDP hearing under section 6330, such a hearing must be
requested during the 30-day period that commences that day after the
date of the CDP Notice.

(2) Questions and answers. The questions and answers illustrate the
provisions of this paragraph (c) as follows:

Q-C1. What must a taxpayer do to obtain a CDP hearing?

A-C1. (i) The taxpayer must make a request in writing for a CDP
hearing. A written request in any form which requests a CDP hearing
will be acceptable. The request must include the taxpayer's name,
address, and daytime telephone number, and must be signed by the
taxpayer or the taxpayer's authorized representative and dated.
Included with the CDP Notice will be a Form 12153, Request for a
Collection Due Process Hearing, that can be used by the taxpayer in
requesting a CDP hearing. The Form 12153 requests the following
information:

(A) The taxpayer's name, address, daytime telephone number, and
taxpayer identification number (SSN or TIN).

(B) The type of tax involved.

(C) The tax period at issue.

(D) A statement that the taxpayer requests a hearing with Appeals
concerning the proposed collection activity.

(E) The reason or reasons why the taxpayer disagrees with the
proposed collection action.

(ii) Taxpayers are encouraged to use a Form 12153 in requesting a
CDP hearing so that such a request can be readily identified and
forwarded to Appeals. Taxpayers may obtain a copy of Form 12153 by
contacting the IRS office that issued the CDP Notice or by calling,
toll free, 1-800-829-3676.

Q-C2. Must the request for the CDP hearing be in writing?

A-C2. Yes. There are several reasons why the request for a CDP
hearing must be in writing. First, the filing of a timely request
for a CDP hearing is the first step in what may result in a court
proceeding. A written request will provide proof that the CDP
hearing was requested and thus permit the court to verify that it
has jurisdiction over any subsequent appeal of the Notice of
Determination issued by Appeals. In addition, the receipt of the
written request will establish the date on which the periods of
limitation under section 6502 (relating to collection after
assessment), section 6531 (relating to criminal prosecutions), and
section 6532 (relating to suits) are suspended as a result of the
CDP hearing and any judicial appeal. Moreover, because the IRS
anticipates that taxpayers will contact the IRS office that issued
the CDP Notice for further information, for help in filling out Form
12153, or in an attempt to resolve their liabilities prior to going
through the CDP hearing process, the requirement of a written
request should help to prevent any misunderstanding as to whether a
CDP hearing has been requested.

If the information requested on Form 12153 is furnished by the
taxpayer, the written request will also help to establish the issues
for which the taxpayer seeks a determination by Appeals.

Q-C3. When must a taxpayer request a CDP hearing with respect to a
CDP Notice issued under section 6330?

A-C3. A taxpayer must submit a written request for a CDP hearing
with respect to a CDP Notice issued under section 6330 within the
30-day period commencing the day after the date of the CDP Notice.
This period is slightly different from the period allowed taxpayers
to submit a written request for a CDP hearing with respect to a CDP
Notice issued under section 6320. For a CDP Notice issued under
section 6320, a taxpayer must submit a written request for a CDP
hearing within the 30-day period commencing the day after the end of
the five business day period following the filing of the notice of
federal tax lien (NFTL).

Q-C4. How will the timeliness of a taxpayer's written request for a
CDP hearing be determined?

A-C4. The rules under section 7502 and the regulations thereunder
and section 7503 and the regulations thereunder will apply to
determine the timeliness of the taxpayer's request for a CDP
hearing, if properly transmitted and addressed as provided in

A-C6 of this paragraph (c)(2).

Q-C5. Is the 30-day period within which a taxpayer must make a
request for a CDP hearing extended because the taxpayer resides
outside the United States?

A-C5. No. Section 6330 does not make provision for such a
circumstance. Accordingly, all taxpayers who want a CDP hearing
under section 6330 must request such a hearing within the 30-day
period commencing the day after the date of the CDP Notice.

Q-C6. Where should the written request for a CDP hearing be sent?

A-C6. The written request for a CDP hearing should be filed with the
IRS office that issued the CDP Notice at the address indicated on
the CDP Notice. If the address of that office is not known, the
request may be sent to the District Director serving the district of
the taxpayer's residence or principal place of business. If the
taxpayer does not have a residence or principal place of business in
the United States, the request may be sent to the Director,
Philadelphia Service Center.

Q-C7. What will happen if the taxpayer does not request a section
6330 CDP hearing in writing within the 30-day period commencing on
the day after the date of the CDP Notice?

A-C7. If the taxpayer does not request a CDP hearing with Appeals
within the 30-day period commencing the day after the date of the
CDP Notice, the taxpayer will forego the right to a CDP hearing
under section 6330 with respect to the tax and tax period or periods
shown on the CDP Notice. In addition, the IRS will be free to pursue
collection action at the conclusion of the 30-day period following
the date of the CDP Notice. The taxpayer may, however, request an
equivalent hearing. See paragraph (i) of this section.

Q-C8. When must a taxpayer request a CDP hearing with respect to a
substitute CDP Notice?

A-C8. A CDP hearing with respect to a substitute CDP Notice must be
requested in writing by the taxpayer prior to the end of the 30-day
period commencing the day after the date of the substitute CDP
Notice.

Q-C9. Can taxpayers attempt to resolve the matter of the proposed
levy with an officer or employee of the IRS office collecting the
tax liability stated on the CDP Notice either before or after
requesting a CDP hearing?

A-C9. Yes. Taxpayers are encouraged to discuss their concerns with
the IRS office collecting the tax, either before or after they
request a CDP hearing. If such a discussion occurs before a request
is made for a CDP hearing, the matter may be resolved without the
need for Appeals consideration. However, these discussions do not
suspend the running of the 30-day period within which the taxpayer
is required to request a CDP hearing, nor do they extend that 30-day
period. If discussions occur after the request for a CDP hearing is
filed and the taxpayer resolves the matter with the IRS office
collecting the tax, the taxpayer may withdraw in writing the request
that a CDP hearing be conducted by Appeals. The taxpayer can also
waive in writing some or all of the requirements regarding the
contents of the Notice of Determination.

(d) Conduct of CDP hearing--(1) In general. If a taxpayer requests a
CDP hearing under section 6330(a)(3)(B) (and does not withdraw that
request), the CDP hearing will be held with Appeals. The taxpayer is
entitled to only one CDP hearing under section 6330 with respect to
the tax and tax period or periods shown on the CDP Notice. To the
extent practicable, the CDP hearing requested under section 6330
will be held in conjunction with any CDP hearing the taxpayer
requests under section 6320. A CDP hearing will be conducted by an
employee or officer of Appeals who has had no involvement with
respect to the tax for the tax period or periods covered by the
hearing prior to the first CDP hearing under section 6320 or section
6330, unless the taxpayer waives that requirement.

(2) Questions and answers. The questions and answers illustrate the
provisions of this paragraph (d) as follows:

Q-D1. Under what circumstances can a taxpayer receive more than one
CDP hearing with respect to a tax period?

A-D1. The taxpayer may receive more than one CDP hearing with
respect to a tax period where the tax involved is a different type
of tax (for example, an employment tax liability, where the original
CDP hearing for the tax period involved an income tax liability), or
where the same type of tax for the same period is involved, but
where the amount of the tax has changed as a result of an additional
assessment of tax for that period or an additional accuracy-related
or filing delinquency penalty has been assessed. The taxpayer is not
entitled to another CDP hearing if the additional assessment
represents accruals of interest or accruals of penalties.

Q-D2. Will a CDP hearing with respect to one tax period be combined
with a CDP hearing with respect to another tax period?

A-D2. To the extent practicable, a hearing with respect to one tax
period shown on a CDP Notice will be combined with any and all other
hearings to which the taxpayer may be entitled with respect to other
tax periods shown on the CDP Notice.

Q-D3. Will a CDP hearing under section 6330 be combined with a CDP
hearing under section 6320?

A-D3. To the extent it is practicable, a CDP hearing under section
6330 will be held in conjunction with a CDP hearing under section
6320.

Q-D4. What is considered to be prior involvement by an employee or
officer of Appeals with respect to the tax and tax period or periods
involved in the hearing?

A-D4. Prior involvement by an employee or officer of Appeals
includes participation or involvement in an Appeals hearing (other
than a CDP hearing held under either section 6320 or section 6330)
that the taxpayer may have had with respect to the tax and tax
period shown on the CDP Notice.

Q-D5. How can a taxpayer waive the requirement that the officer or
employee of Appeals had no prior involvement with respect to the tax
and tax period or periods?

A-D5. The taxpayer must sign a written waiver.

(e) Matters considered at CDP hearing--(1) In general.

Appeals has the authority to determine the validity, sufficiency,
and timeliness of any CDP Notice given by the IRS and of any request
for a CDP hearing that is made by a taxpayer. Prior to issuance of a
determination, the hearing officer is required to obtain
verification from the IRS office collecting the tax that the
requirements of any applicable law or administrative procedure have
been met. The taxpayer may raise any relevant issue relating to the
unpaid tax at the hearing, including appropriate spousal defenses,
challenges to the appropriateness of the proposed collection action,
and offers of collection alternatives. The taxpayer also may raise
challenges to the existence or amount of the tax liability for any
tax period shown on the CDP Notice if the taxpayer did not receive a
statutory notice of deficiency for that tax liability or did not
otherwise have an opportunity to dispute that tax liability.
Finally, the taxpayer may not raise an issue that was raised and
considered at a previous CDP hearing under section 6320 or in any
other previous administrative or judicial proceeding if the taxpayer
participated meaningfully in such hearing or proceeding.

Taxpayers will be expected to provide all relevant information
requested by Appeals, including financial statements, for its
consideration of the facts and issues involved in the hearing.

(2) Spousal defenses. A taxpayer may raise any appropriate spousal
defenses at a CDP hearing. To claim a spousal defense under section
6015, the taxpayer must do so in writing according to rules
prescribed by the Secretary. Spousal defenses raised under section
6015 in a CDP hearing are governed in all respects by the provisions
of section 6015 and the procedures prescribed by the Secretary
thereunder.

(3) Questions and answers. The questions and answers illustrate the
provisions of this paragraph (e) as follows:

Q-E1. What factors will Appeals consider in making its
determination?

A-E1. Appeals will consider the following matters in making its
determination:

(i) Whether the IRS met the requirements of any applicable law or
administrative procedure.

(ii) Any issues appropriately raised by the taxpayer relating to the
unpaid tax.

(iii) Any appropriate spousal defenses raised by the taxpayer.

(iv) Any challenges made by the taxpayer to the appropriateness of
the proposed collection action.

(v) Any offers by the taxpayer for collection alternatives.

(vi) Whether the proposed collection action balances the need for
the efficient collection of taxes and the legitimate concern of the
taxpayer that any collection action be no more intrusive than
necessary.

Q-E2. When is a taxpayer entitled to challenge the existence or
amount of the tax liability specified in the CDP Notice?

A-E2. A taxpayer is entitled to challenge the existence or amount of
the tax liability specified in the CDP Notice if the taxpayer did
not receive a statutory notice of deficiency for such liability or
did not otherwise have an opportunity to dispute such liability.
Receipt of a statutory notice of deficiency for this purpose means
receipt in time to petition the Tax Court for a redetermination of
the deficiency asserted in the notice of deficiency. An opportunity
to dispute a liability includes a prior opportunity for a conference
with Appeals that was offered either before or after the assessment
of the liability.

Q-E3. Are spousal defenses subject to the limitations imposed under
section 6330(c)(2)(B) on a taxpayer's right to challenge the tax
liability specified in the CDP Notice at a CDP hearing?

A-E3. No. The limitations imposed under section 6330(c)(2)(B) do not
apply to spousal defenses. A spousal defense raised under section
6015 is governed by that section; therefore any limitations under
section 6015 will apply.

Q-E4. May a taxpayer raise at a CDP hearing a spousal defense under
section 6015 if that defense was raised and considered in a prior
judicial proceeding that has become final?

A-E4. No. A taxpayer is precluded by limitations under section 6015
from raising a spousal defense under section 6015 in a CDP hearing
under these circumstances.

Q-E5. What collection alternatives are available to the taxpayer?

A-E5. Collection alternatives would include, for example, a proposal
to withhold the proposed or future collection action in
circumstances that will facilitate the collection of the tax
liability, an installment agreement, an offer-in-compromise, the
posting of a bond, or the substitution of other assets.

Q-E6. What issues may a taxpayer raise in a CDP hearing under
section 6330 if he previously received a notice under section 6320
with respect to the same tax and tax period and did not request a
CDP hearing with respect to that notice?

A-E6. The taxpayer may raise appropriate spousal defenses,
challenges to the appropriateness of the proposed collection action,
and offers of collection alternatives. The existence or amount of
the tax liability for the tax for the tax period shown in the CDP
Notice may be challenged only if the taxpayer did not already have
an opportunity to dispute that tax liability. Where the taxpayer
previously received a CDP Notice under section 6320 with respect to
the same tax and tax period and did not request a CDP hearing with
respect to that earlier CDP Notice, the taxpayer already had an
opportunity to dispute the existence or amount of the underlying tax
liability.

Q-E7. How will Appeals issue its determination?

A-E7. (i) Taxpayers will be sent a dated Notice of Determination by
certified or registered mail. The Notice of Determination will set
forth Appeals's findings and decisions:

(A) It will state whether the IRS met the requirements of any
applicable law or administrative procedure.

(B) It will resolve any issues appropriately raised by the taxpayer
relating to the unpaid tax.

(C) It will include a decision on any appropriate spousal defenses
raised by the taxpayer.

(D) It will include a decision on any challenges made by the
taxpayer to the appropriateness of the collection action.

(E) It will respond to any offers by the taxpayer for collection
alternatives.

(F) It will address whether the proposed collection action
represents a balance between the need for the efficient collection
of taxes and the legitimate concern of the taxpayer that any
collection action be no more intrusive than necessary.

(ii) The Notice of Determination will also set forth any agreements
that Appeals reached with the taxpayer, any relief given the
taxpayer, and any actions the taxpayer and/or the IRS are required
to take. Lastly, the Notice of Determination will advise the
taxpayer of his right to seek judicial review within 30 days of the
date of the Notice of Determination.

(iii) Because taxpayers are encouraged to discuss their concerns
with the IRS office collecting the tax or filing the NFTL, certain
matters that might have been raised at a CDP hearing may be resolved
without the need for Appeals consideration. Unless as a result of
these discussions, the taxpayer agrees in writing to withdraw the
request that Appeals conduct a CDP hearing, Appeals will still issue
a Notice of Determination, but the taxpayer can waive in writing
Appeals's consideration of some or all of the matters it would
otherwise consider in making its determination.

Q-E8. Is there a time limit on the CDP hearings or on when Appeals
must issue a Notice of Determination?

A-E8. No. Appeals will, however, attempt to conduct CDP hearings as
expeditiously as possible.

Q-E9. Why is the Notice of Determination and its date important?

A-E9. The Notice of Determination will set forth Appeals's findings
and decisions with respect to the matters set forth in

A-E1 of this paragraph (e)(3). The date of the Notice of
Determination establishes the beginning date of the 30-day period
within which the taxpayer is permitted to seek judicial review of
Appeals's determination.

(4) Examples. The following examples illustrate the principles of
this paragraph (e).

Example 1. The IRS sends a statutory notice of deficiency to the
taxpayer at his last known address asserting a deficiency for the
tax year 1995. The taxpayer receives the notice of deficiency in
time to petition the Tax Court for a redetermination of the asserted
deficiency. The taxpayer does not timely file a petition with the
Tax Court. The taxpayer is therefore precluded from challenging the
existence or amount of the tax liability in a subsequent CDP
hearing.

Example 2. Same facts as in Example 1, except the taxpayer does not
receive the notice of deficiency in time to petition the Tax Court.
The taxpayer is not, therefore, precluded from challenging the
existence or amount of the tax liability in a subsequent CDP
hearing.

Example 3. The IRS properly assesses a trust fund recovery penalty
against the taxpayer. The IRS offers the taxpayer the opportunity
for a conference at which the taxpayer would have the opportunity to
dispute the assessed liability. The taxpayer declines the
opportunity to participate in such a conference.

The taxpayer is precluded from challenging the existence or amount
of the tax liability in a subsequent CDP hearing.

(f) Judicial review of Notice of Determination

B-(1) In general. Unless the taxpayer provides the IRS a written
withdrawal of the request that Appeals conduct a CDP hearing,
Appeals is required to issue a Notice of Determination in all cases
where a taxpayer has timely requested a CDP hearing. The taxpayer
may appeal such determinations made by Appeals within 30 days after
the date of the Notice of Determination to the Tax Court or a
district court of the United States, as appropriate.

(2) Questions and answers. The questions and answers illustrate the
provisions of this paragraph (f) as follows:

Q-F1. What must a taxpayer do to obtain judicial review of a Notice
of Determination?

A-F1. Subject to the jurisdictional limitations described in A-F2 of
this paragraph (f)(2), the taxpayer must, within the 30-day period
commencing the day after the date of the Notice of Determination,
appeal Appeals's determination to the Tax Court or to a district
court of the United States.

Q-F2. With respect to the relief available to the taxpayer under
section 6015(b) or (c), what is the time frame within which a
taxpayer may seek Tax Court review of Appeals's determination
following a CDP hearing?

A-F2. If the taxpayer seeks Tax Court review not only of Appeals's
denial of relief under section 6015(b) or (c), but also of relief
with respect to other issues raised in the CDP hearing, the taxpayer
should request Tax Court review within the 30-day period commencing
the day after the date of the Notice of Determination. If the
taxpayer only wants Tax Court review of Appeals's denial of relief
under section 6015(b) or (c), the taxpayer should request review by
the Tax Court, as provided by section 6015(e), within 90 days of
Appeals's determination. If a request for Tax Court review is filed
after the 30-day period for seeking judicial review under section
6330, then only the taxpayer's section 6015(b) or (c) claims may be
reviewable by the Tax Court.

Q-F3. Where should a taxpayer direct a request for judicial review
of a Notice of Determination?

A-F3. If the Tax Court would have jurisdiction over the type of tax
specified in the CDP Notice (for example, income and estate taxes),
then the taxpayer must seek judicial review by the Tax Court. If the
tax liability arises from a type of tax over which the Tax Court
would not have jurisdiction, then the taxpayer must seek judicial
review by a district court of the United States in accordance with
Title 28 of the United States Code.

Q-F4. What happens if the taxpayer timely appeals Appeals's
determination to the incorrect court?

A-F4. If the court to which the taxpayer directed a timely appeal of
the Notice of Determination determines that the appeal was to the
incorrect court (because of jurisdictional, venue or other reasons),
the taxpayer will have 30 days after the court's determination to
that effect within which to file an appeal to the correct court.

Q-F5. What issue or issues may the taxpayer raise before the Tax
Court or before a district court if the taxpayer disagrees with the
Notice of Determination?

A-F5. In seeking Tax Court or district court review of Appeals's
Notice of Determination, the taxpayer can only ask the court to
consider an issue that was raised in the taxpayer's CDP hearing.

(g) Effect of request for CDP hearing and judicial review on periods
of limitation--(1) In general. The periods of limitation under
section 6502 (relating to collection after assessment), section 6531
(relating to criminal prosecutions), and section 6532 (relating to
suits) are suspended until the date the IRS receives the taxpayer's
written withdrawal of the request for a CDP hearing by Appeals or
the determination resulting from the CDP hearing becomes final by
expiration of the time for seeking review or reconsideration. In no
event shall any of these periods of limitation expire before the
90th day after the date on which the determination with respect to
such hearing becomes final upon expiration of the time for seeking
review or reconsideration.

(2) Questions and answers. The questions and answers.36 illustrate
the provisions of this paragraph (g) as follows:

Q-G1. For what period of time will the periods of limitation under
section 6502, section 6531, and section 6532 remain suspended if the
taxpayer timely requests a CDP hearing concerning a pre-levy or
post-levy CDP Notice?

A-G1. The suspension period commences on the date the IRS receives
the taxpayer's written request for a CDP hearing. The suspension
period continues until the IRS receives a written withdrawal by the
taxpayer of the request for a CDP hearing or the determination
resulting from the CDP hearing becomes final by expiration of the
time for seeking its review or reconsideration.

In no event shall any of these periods of limitation expire before
the 90th day after the day on which there is a final determination
with respect to such hearing. The periods of limitation that are
suspended under section 6330 are those which apply to the taxes and
the tax period or periods to which the CDP Notice relates.

Q-G2. For what period of time will the periods of limitation under
section 6502, section 6531, and section 6532 be suspended if the
taxpayer does not request a CDP hearing concerning the CDP Notice,
or the taxpayer requests a CDP hearing, but his request is not
timely?

A-G2. Under either of these circumstances, section 6330 does not
provide for a suspension of the periods of limitation.

(3) Examples. The following examples illustrate the principles of
this paragraph (g).

Example 1. The period of limitation under section 6502 with respect
to the taxpayer's tax period listed in the CDP Notice will expire on
August 1, 1999. The IRS sent a CDP Notice to the taxpayer on April
30, 1999. The taxpayer timely requested a CDP hearing. The IRS
received this request on May 15, 1999. Appeals sends the taxpayer
its determination on June 15, 1999. The taxpayer timely seeks
judicial review of that determination. The period of limitation
under section 6502 would be suspended from May 15, 1999, until the
determination resulting from that hearing becomes final by
expiration of the time for seeking review or reconsideration before
the appropriate court, plus 90 days.

Example 2. Same facts as in Example 1, except the taxpayer does not
seek judicial review of Appeals's determination.

Because the taxpayer requested the CDP hearing when fewer than 90
days remained on the period of limitation, the period of limitation
will be extended to October 13, 1999 (90 days from July 15, 1999).

(h) Retained jurisdiction of Appeals--(1) In general. The Appeals
office that makes a determination under section 6330 retains
jurisdiction over that determination, including any subsequent
administrative hearings that may be requested by the taxpayer
regarding levies and any collection actions taken or proposed with
respect to Appeals's determination. Once a taxpayer has exhausted
his other remedies, Appeals's retained jurisdiction permits it to
consider whether a change in the taxpayer's circumstances affects
its original determination.

Where a taxpayer alleges a change in circumstances that affects
Appeals's original determination, Appeals may consider whether
changed circumstances warrant a change in its earlier determination.

(2) Questions and answers. The questions and answers illustrate the
provisions of this paragraph (h) as follows:

Q-H1. Are the periods of limitation suspended during the.38 course
of any subsequent Appeals consideration of the matters raised by a
taxpayer when the taxpayer invokes the retained jurisdiction of
Appeals under section 6330(d)(2)(A) or (d)(2)(B)?

A-H1. No. Under section 6330(b)(2), a taxpayer is entitled to only
one section 6330 CDP hearing with respect to the tax and tax period
or periods to which the unpaid tax relates. Any subsequent
consideration by Appeals pursuant to its retained jurisdiction is
not a continuation of the original CDP hearing and does not suspend
the periods of limitation.

Q-H2. Is a decision of Appeals resulting from a subsequent hearing
appealable to the Tax Court or a district court?

A-H2. No. As discussed in A-H1, a taxpayer is entitled to only one
section 6330 CDP hearing with respect to the tax and tax period or
periods specified in the CDP Notice. Only determinations resulting
from CDP hearings are appealable to the Tax Court or a district
court.

(i) Equivalent hearing--(1) In general. A taxpayer who fails to make
a timely request for a CDP hearing is not entitled to a CDP hearing.
Such a taxpayer may nevertheless request an administrative hearing
with Appeals, which is referred to herein as an A equivalent
hearing.

@ The equivalent hearing will be held by Appeals and will generally
follow Appeals procedures for a CDP hearing. Appeals will not,
however, issue a Notice of Determination. Under such circumstances,
Appeals will issue a Decision Letter.

(2) Questions and answers. The questions and answers.39 illustrate
the provisions of this paragraph (i) as follows:

Q-I1. What issues will Appeals consider at an equivalent hearing?

A-I1. In an equivalent hearing, Appeals will consider the same
issues that it would have considered at a CDP hearing on the same
matter.

Q-I2. Are the periods of limitation under sections 6502, 6531, and
6532 suspended if the taxpayer does not timely request a CDP hearing
and is subsequently given an equivalent hearing?

A-I2. No. The suspension period provided for in section 6330(e)
relates only to hearings requested within the 30-day period that
commences the day following the date of the pre-levy or post-levy
CDP Notice, that is, CDP hearings.

Q-I3. Will collection action be suspended if a taxpayer requests and
receives an equivalent hearing?

A-I3. Collection action is not required to be suspended.

Accordingly, the decision to take collection action during the
pendency of an equivalent hearing will be determined on a case-by-
case basis. Appeals may request the IRS office with responsibility
for collecting the taxes to suspend all or some collection action or
to take other appropriate action if it determines that such action
is appropriate or necessary under the circumstances.

Q-I4. What will the Decision Letter state?

A-I4. The Decision Letter will generally contain the same
information as a Notice of Determination..40

Q-I5. Will a taxpayer be able to obtain court review of a decision
made by Appeals with respect to an equivalent hearing?

A-I5. Section 6330 does not authorize a taxpayer to appeal the
decision of Appeals with respect to an equivalent hearing. A
taxpayer may under certain circumstances be able to seek Tax Court
review of Appeals's denial of relief under section 6015(b) or (c).
Such review must be sought within 90 days of the issuance of
Appeals's determination on those issues, as provided by section
6015(e).

(j) Effective date. This section is applicable with respect to any
levy which occurs on or after January 19, 1999, and before January
22, 2002.

Robert E. Wenzel
Deputy Commissioner of Internal Revenue
Approved: January 13, 1999
Donald C. Lubick
Assistant Secretary of the Treasury

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