- 4 - On June 11, 2001, petitioner filed a Petition for Lien or Levy Action Under Code Section 6320(c) or 6330(d). On August 30, 2001, petitioner filed an Amended Petition for Lien or Levy Action Under Code Section 6320(c) or 6330(d). OPINION In the amended petition, petitioner argues that (1) respondent denied her right to a “Due Process Hearing under IRC 6320" alleging that respondent ignored petitioner’s telephone calls to reschedule the hearing; and (2) she is entitled to a filing status as “Head of Household” because she sent proofs of eligibility to respondent. Respondent contends that (1) petitioner was afforded the opportunity for a hearing but waived that right when she failed to cooperate; and (2) under section 6330(c)(2)(B), petitioner is precluded from challenging her 1992 liability because she received a notice of deficiency for 1992. Section 6321 provides that, if any person liable to pay any tax neglects or refuses to do so after demand, the amount 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. Pursuant to section 6323, the Commissioner generally is required to file a Notice of Federal Tax Lien with the appropriate State office for the lien to be valid against certain third parties.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011