Janie M. Dixon and Joseph Dixon, Jr. - Page 7

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          fact regarding the collection matters, other than Ms. Dixon’s               
          request for spousal relief, in this case.                                   
          I.  Collection Actions--General Rules                                       
               Section 6321 imposes a lien in favor of the United States              
          upon all property and rights to property of a taxpayer where                
          there exists a failure to pay any tax liability after demand for            
          payment.  The lien generally arises at the time assessment is               
          made.  Sec. 6322.  Section 6323, however, provides that such lien           
          shall not be valid against any purchaser, holder of a security              
          interest, mechanic’s lienor, or judgment lien creditor until the            
          Secretary files a notice of lien with the appropriate public                
          officials.                                                                  
               Section 6320 then sets forth procedures applicable to afford           
          protections for taxpayers in lien situations.  Section 6320(a)(1)           
          establishes the requirement that the Secretary notify in writing            
          the person described in section 6321 of the filing of a notice of           
          lien under section 6323.  This notice required by section 6320              
          must be sent not more than 5 business days after the notice of              
          tax lien is filed and must advise the taxpayer of the opportunity           
          for administrative review of the matter in the form of a hearing            
          before the Internal Revenue Service Office of Appeals.  Sec.                
          6320(a)(2) and (3).  Section 6320(b) and (c) grants a taxpayer,             
          who so requests, the right to a fair hearing before an impartial            








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