John Thurman Horejs - Page 7

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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.              
               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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