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OPINION
All property and rights to property of a taxpayer become
subject to a lien in favor of the United States on the date a tax
liability is assessed against a taxpayer, if the taxpayer fails
to pay the tax liability after notice and demand for payment.
Secs. 6321 and 6322. Until an NFTL is filed, however, the lien
is without validity and priority against certain persons such as
judgment lien creditors of the taxpayer. Sec. 6323(a).
After the Commissioner files the NFTL, the Commissioner must
provide the taxpayer with written notice of the filing, informing
the taxpayer of his right to request an administrative hearing on
the matter. Sec. 6320(a)(1), (3)(B). If the taxpayer makes a
timely request for an administrative hearing, section 6320(c)
requires that the hearing be conducted pursuant to section
6330(c), (d), and (e). Section 6330(c)(2) provides that a person
may raise any relevant issue relating to the disputed collection
action and may contest the existence or amount of the underlying
tax liability if the person did not receive a notice of
deficiency or did not otherwise have the opportunity to dispute
the underlying tax liability. See also Sego v. Commissioner, 114
T.C. 604, 610 (2000); Goza v. Commissioner, 114 T.C. 176, 180-181
(2000).
Following the hearing, the hearing officer is required to
issue a notice of determination regarding the disputed collection
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