-5-
Commissioner, 90 T.C. 678, 681 (1988). Summary judgment may be
granted with respect to all or any part of the legal issues in
controversy “if the pleadings, answers to interrogatories,
depositions, admissions, and any other acceptable materials,
together with the affidavits, if any, show that there is no
genuine issue as to any material fact and that a decision may be
rendered as a matter of law.” Rule 121(a) and (b); Sundstrand
Corp. v. Commissioner, 98 T.C. 518, 520 (1992), affd. 17 F.3d 965
(7th Cir. 1994). The moving party bears the burden of proving
that there is no genuine issue of material fact, and factual
inferences are drawn in a manner most favorable to the party
opposing summary judgment. Dahlstrom v. Commissioner, 85 T.C.
812, 821 (1985); Jacklin v. Commissioner, 79 T.C. 340, 344
(1982).
As will be shown in the discussion that follows, petitioner
has raised no genuine issue as to any material fact.
Accordingly, we conclude that this case is ripe for summary
judgment.
Section 6321 imposes a lien in favor of the United States on
all of a person’s property and rights to property where such
person is liable to pay any tax and neglects or refuses to pay
the same after demand. Under section 6322 the lien arises at the
time the assessment is made and continues until the liability for
the amount so assessed is paid. Section 6323(a) requires the
Secretary to file a notice of Federal tax lien in order for the
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