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1994 tax liabilities. On August 30, 2001, petitioner filed an
amended petition for lien or levy action under Code section
6320(c) or 6330(d).
On November 20, 2002, respondent filed a motion for summary
judgment. Attached as exhibits to the motion for summary
judgment are three different kinds of transcripts of account--
dated October 12, 2000, November 16, 2000, and January 26, 2001--
and Forms 4340, Certificate of Assessments, Payments and Other
Specified Matters--dated July 12, 2002--for petitioner’s 1989,
1990, 1991, 1992, 1993, and 1994 tax years.
On November 21, 2002, the Court ordered petitioner to file
any objection to respondent’s motion for summary judgment on or
before December 12, 2002. On December 17, 2002, petitioner filed
a response to respondent’s motion for summary judgment
(response).
Discussion
Section 6320 provides that the Secretary shall furnish the
person described in section 6321 with written notice (i.e., the
hearing notice) of the filing of a notice of lien under section
6323. The hearing notice is to be furnished not more than 5
business days after the filing of the notice of lien. Sec.
6320(a)(2). Section 6320 further provides that the taxpayer may
request administrative review of the matter (in the form of a
hearing) within the 30-day period beginning on the day after the
5-day period described above. The hearing generally shall be
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