Internal Revenue Code section 6330 is the center of the federal Collection Due Process system for proposed levies. It requires the IRS to give written notice of hearing rights and establishes the framework for review by the IRS Independent Office of Appeals.
The deadline controls the procedure
The notice states the period for requesting the hearing. A timely request generally provides stronger procedural protection than an equivalent-hearing request filed after the statutory window. The notice number, notice date, covered tax periods, filing address, and response deadline should be checked immediately.
What Appeals considers
The Appeals officer verifies that applicable legal and administrative requirements were satisfied. The taxpayer may raise relevant collection issues, including appropriate collection alternatives. In limited circumstances, the taxpayer may challenge the existence or amount of the underlying liability. The statute also calls for balancing efficient collection against unnecessary intrusiveness.
A hearing is procedure, not a promised result
A timely hearing request can protect rights, but it does not establish eligibility for an installment agreement, hardship status, offer in compromise, or other resolution. Those questions depend on compliance, financial facts, account history, and the standards governing the requested alternative.