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On February 27, 2001, petitioner filed one petition with
this Court for review of both of respondent’s notices of
determination.
On February 27, 2001, petitioner’s motion to dismiss was
filed. On May 21, 2001, respondent’s motion with respect to the
frivolous return penalty was filed.
Section 6321 imposes a lien in favor of the United States on
all property and rights to property of a person liable for taxes
when a demand for the payment of such 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 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
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 described above. Section 6320(c) provides
that the Appeals Office hearing generally shall be conducted
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Last modified: May 25, 2011