- 8 - 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 bePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011