Lottie Tyler Richardson - Page 7

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          session in Washington, D.C., on November 6, 2002.  Petitioner and           
          respondent both appeared at the hearing and presented their                 
          positions with respect to the tax lien filed against petitioner.            
                                     Discussion                                       
               All property and rights to property of a taxpayer become               
          subject to a lien in favor of the United States on the date a tax           
          liability is assessed against the taxpayer, if the taxpayer fails           
          to meet the Commissioner’s demand for payment of her tax                    
          liability.  Secs. 6321 and 6322.  Until a Notice of Federal Tax             
          Lien is filed, a lien is without validity and priority against              
          certain persons such as judgment lien creditors of the taxpayer.            
          Sec. 6323(a).  After the Secretary files the Notice of Federal              
          Tax Lien, the Secretary must provide the taxpayer with written              
          notice of the filing, informing the taxpayer of her right to                
          request an administrative hearing on the matter.  Sec.                      
          6320(a)(1), (3)(B).  Section 6320(c) requires that the                      
          administrative hearing be conducted pursuant to section 6330(c),            
          (d), and (e).  Following the hearing, the hearing officer is                
          required to issue a notice of determination regarding the                   
          disputed Notice of Federal Tax Lien.  If the taxpayer disagrees             
          with the hearing officer’s determination, the taxpayer has the              
          right to seek judicial review of the Appeals officer’s                      
          determination by appealing to this Court or, if this Court lacks            
          jurisdiction over the underlying tax liability, to the proper               






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