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OPINION
Section 6321 imposes a lien in favor of the United States
upon all property and rights to property belonging to a person
liable for unpaid taxes after demand for payment has been made.
Within 5 business days after the day of filing the notice of
lien, the Secretary must notify the taxpayer, in writing, that a
tax lien was filed and inform the taxpayer of his/her right to a
hearing before an impartial Appeals officer. Sec. 6320.
Pursuant to section 6320(c), the hearing is to be conducted
consistent with procedures set forth in subsections (c), (d)
(other than paragraph (2)(B) thereof), and (e) of section 6330.
If the Commissioner issues a determination letter adverse to the
position of the taxpayer, the taxpayer may seek judicial review
of that determination. Sec. 6330(d).
Preliminarily we deal with a jurisdictional issue.
Petitioner maintains that we should consider his income and
employment tax liabilities together because the assigned IRS
revenue officer pursued the collection of petitioner’s income tax
liabilities in conjunction with his employment tax liabilities.
Respondent, on the other hand, objects to petitioner’s raising of
respondent’s collection activities of petitioner’s employment tax
liability. Respondent maintains that the lien in question
pertains only to petitioner’s unpaid income taxes for 1996-99,
not petitioner’s unpaid employment taxes. In this regard,
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Last modified: May 25, 2011