-4-
As will be shown in the discussion that follows, petitioner
has raised no genuine issue as to any material fact.
Accordingly, we shall grant respondent’s motion for summary
judgment.
Section 6321 imposes a lien in favor of the United States on
all of a person’s property and rights to property where the
person is liable to pay any tax and neglects or refuses to pay
the same after demand. Under section 6322, the lien arises at
the time the assessment is made and continues until the liability
for the amount so assessed is paid. Section 6323(a) requires the
Secretary to file a notice of Federal tax lien in order for the
lien 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. Section 6320(c) provides that the
Appeals Office hearing generally shall be conducted consistent
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