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Forms 4340, with regard to petitioner’s account for 1995 and 1996
satisfied the verification requirement imposed under section
6330(c)(1) and demonstrates that petitioner was issued notices
and demands for payment on the same dates that respondent entered
the assessments in question. Finally, respondent contends that
petitioner’s behavior warrants the imposition of a penalty under
section 6673.
Petitioner filed an objection to respondent’s motion.
Thereafter, pursuant to notice, respondent’s motion was called
for hearing at the Court’s motions session in Washington, D.C.
Discussion
Section 6321 imposes a lien in favor of the United States on
all property and rights to property of a person when a demand for
the payment of the person’s liability for taxes has been made and
the person fails to pay those taxes. Such a lien arises when an
assessment is made. Sec. 6322. Section 6323(a) requires the
Secretary to file a notice of Federal tax lien if such lien is to
be valid against any purchaser, holder of a security interest,
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
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