Willie R. Davidson - Page 10




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          mechanic’s lienor, or judgment lien creditor.  Lindsay v.                   
          Commissioner, T.C. Memo. 2001-285.                                          
               Section 6320 provides that the Secretary shall furnish the             
          person described in section 6321 with written notice of the                 
          filing of a notice of lien under section 6323.  The notice                  
          required by section 6320 must be provided not more than 5                   
          business days after the day of the filing of the notice of lien.            
          Sec. 6320(a)(2).  Section 6320 further provides that the person             
          may request administrative review of the matter (in the form of             
          an Appeals Office hearing) within 30 days beginning on the day              
          after the 5-day period.  Section 6320(c) provides that the                  
          Appeals Office hearing generally shall be conducted consistent              
          with the procedures set forth in section 6330(c), (d), and (e).             
               Section 6331(a) provides that if any person liable to pay              
          any tax neglects or refuses to pay such tax within 10 days after            
          notice and demand for payment, the Secretary is authorized to               
          collect such tax by levy on the person’s property.  Section                 
          6331(d) provides that at least 30 days before enforcing                     
          collection by levy on the person's property, the Secretary is               
          obliged to provide the person with a final notice of intent to              
          levy, including notice of the administrative appeals available to           
          the person.                                                                 
               Section 6330 generally provides that the Commissioner cannot           
          proceed with collection by levy until the person has been given             






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