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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.
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Last modified: May 25, 2011