Collection Due Process - Levy

ID: CCA_2009090213262962 Number: 200941030
Release Date: 10/9/2009
Office: ---
UILC: 6330.00-00
From: ---
Sent: Wednesday, September 02, 2009 1:27:01 PM
To: ---
Cc:
Subject: RE: CDP & Closing Agreement Question
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If the taxpayer, in connection with a closing agreement, has waived the right to a CDP hearing under sections 6320 and 6330, and has waived rights to notice of his/her hearing rights, then he/she is not entitled to the hearings or notice of the hearing rights. If a notice of federal tax lien is filed, then he/she should be sent notice of the lien filing without the notice of the hearing right. Similarly, when a levy is planned, the taxpayer should be given notice of intent to levy (unless jeopardy exists) but should not be given notice of his/her right to a hearing.