Alan C. and Esther R. Schwemmer - Page 6

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               Section 6321 imposes a lien in favor of the United States on           
          all property and rights to property of a person when demand for             
          payment of that person’s liability for taxes has been made and              
          the person fails to pay those taxes.  The lien arises when the              
          assessment is made.  Sec. 6322.  Section 6323(a) requires the               
          Secretary to file notice of Federal tax lien if such lien is 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, affd. 56 Fed. Appx. 800 (9th             
          Cir. 2003).                                                                 
               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 the notice of lien is filed.  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 the 30-day period beginning on the           
          day after the 5-day period described above.  Section 6320(c)                
          provides that the Appeals Office hearing generally shall be                 
          conducted consistent with the procedures set forth in section               
          6330(c), (d), and (e).                                                      
               Section 6330(c) provides for review with respect to                    
          collection issues such as spousal defenses, the appropriateness             

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