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abuse of discretion. Sego v. Commissioner, supra at 610.
Section 6321 imposes a lien in favor of the United States on all
property and rights to property of a person when demand for
payment of that person's liability for taxes has been made and
the person fails to pay those taxes. The lien arises when the
assessment is made. Sec. 6322. Section 6323(a) requires the
Secretary to file an FTL notice 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 (i.e., the
hearing notice) of the filing of a notice of lien under section
6323. The hearing notice must be provided not more than 5
business days after the day the FTL notice is filed. Sec.
6320(a)(2). Section 6320 further provides that the taxpayer may
request administrative review of the matter (in the form of an
Appeals Office hearing) within the 30-day period beginning on the
day after the 5-day period described above. The Appeals Office
hearing generally shall be conducted consistent with the
procedures set forth in section 6330(c), (d), and (e). Sec.
6320(c).
Petitioners claim that the FTL notices were filed on August
27, 1999, when the register’s office recorded the FTL notices,
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