Collection Due Process - Lien

ID:
Office:
UILC:
CCA_2009010616223162
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6320.00-00
Number: 200910035
Release Date: 3/6/2009
From: ---
Sent: Tuesday, January 06, 2009 4:22:35 PM
To: ---
Cc: ---
Subject: RE: CDP question
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Did we answer your question? If not, the answer is yes. If a taxpayer receives a prior section 6330 notice with respect to a tax liability and does not request a hearing, and then later requests a timely section 6320 hearing with respect to the same tax liability, then the prior section 6330 notice is a prior opportunity to dispute the liability under section 6330(c)(2)(B). This position is supported by 301.6320-1(e)(3) Q&A-E2, as you've pointed out. The Tax Court has not ruled on this question directly.
Hope you had a nice holiday season.
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