Howard and Everlina Washington v. Commissioner

I. Introduction

I concur with the conclusion of the majority that respondent may proceed with the collection action as determined in the notice of determination with respect to each of petitioners’ taxable years 1994, 1995, and 1998. I write separately principally to add some observations concerning what we have characterized as the “standard of review” (described infra) applicable to our jurisdiction under section 6330(d)(1) to review a section 6330 determination.

II. Section 6330

Section 6330 entitles a taxpayer to notice and an opportunity for a hearing before certain lien and levy actions…