Joyce E. Beery - Page 6

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          (7th Cir. 1994); Zaentz v. Commissioner, 90 T.C. 753, 754 (1988);           
          Naftel v. Commissioner, 85 T.C. 527, 529 (1985).                            
               The record in this case reflects that there is no dispute as           
          to a material fact.  We agree with respondent that he is entitled           
          to judgment as a matter of law.                                             
          Lien and Levy Actions                                                       
               Section 6321 imposes a lien in favor of the United States on           
          all property and rights to property of a person liable for taxes            
          when a demand for the payment of the taxes has been made and the            
          person fails to pay those taxes.  Section 6322 provides that the            
          lien imposed under section 6321 generally arises when the                   
          Commissioner makes an assessment.  However, section 6323(a)                 
          provides that the lien imposed under section 6321 is not valid              
          against any purchaser, holder of a security interest, mechanic’s            
          lienor, or judgment lien creditor until the Secretary has filed a           
          notice of Federal tax lien with the appropriate authorities.                
          Behling v. Commissioner, 118 T.C. 572, 575 (2002).                          
               Section 6320 provides that the Secretary shall furnish the             
          person described in section 6321 with written notice of the                 
          filing of a Federal tax lien under section 6323.  Such notice               
          must be provided not more than 5 business days after the day of             
          the filing of the notice of lien.  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)             






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