§6630

No similar regula- tory exception existed (or was needed) in Romano-Murphy and that case is there- fore distinguishable from this one. Finally, it is clear that SO2 discharged all ofher other responsibilities under section 6630(c)(3).

to Permit Levy filed November 14,_2008, is granted pursuant to section 6630 .(e)(2), and the levy action that is the basis of this proceeding is not .

Regs ., concluding that a prior opportunity to dispute a liability, for purposes of section 6630(c)(2)(B), did not require an opportunity for judicial review of the liability .

Section 6630(e)(1) provides that levy actions which are the subject ofa requested hearing shall be suspended for the period during which such hearing, and appeals, are pending.

The supplemental CDP hearing allows the parties to complete the initial section 6630 hearing while preserving the taxpayer's right to receivejudicial review ofthe ultimate administrative determination.

Although having a transcript of the administrative hearing under section 6630(b) (and section 6320(b)) might “facilitate” in an appropriate case review of the Appeals’ determination made under section 6330(c)(3), it is a non sequitur to conclude that, therefore, section 7521(a)(1) requires that a taxpayer have the right to make an audio recording of a hearing 6(...continued) which event our standard of review is

IRC section 6630(a) states that no levy may be made unless the IRS notifies a taxpayer of the opportunity for a hearing with the IRS Office of Appeals. Notice CP 523 "Notice of Intent to Levy" was mailed to you via certified mail. You made a timely request for a hear- ing. IRC section 6330(c) allows you to raise any relevant issue relating to the unpai