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that he intended to become a permanent resident in California
when he was hired for a television show to be produced in
California, and that his permanent relationship commenced with a
contract dated July 10, 1996. He then asserted: “On July 25,
1996 I was a resident of the state of California, and not a
resident in any location whatsoever in the state of Florida.”
Respondent’s Motion for Summary Judgment was withdrawn without a
ruling by the Court.
OPINION
Section 6321 provides:
SEC. 6321. LIEN FOR TAXES.
If any person liable to pay any tax neglects or
refuses to pay the same after demand, the amount
(including any interest, additional amount, addition to
tax, or assessable penalty, together with any costs
that may accrue in addition thereto) shall be a lien in
favor of the United States upon all property and rights
to property, whether real or personal, belonging to
such person.
The lien generally arises at the time the assessment is made.
Sec. 6322. Under section 6323, the lien is not valid against any
purchaser, holder of a security interest, mechanic’s lienor, or
judgment lien creditor until a notice of Federal tax lien meeting
the requirements of section 6323(f) has been filed.
Section 6323(f)(1) specifies that a notice of Federal tax
lien shall be filed as follows:
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Last modified: May 25, 2011