- 6 - she timely submitted a Form 12153, she was given a Collection Due Process Hearing to satisfy the requirements under section 6320 and section 6330, and the validity and priority of the Government’s lien is not conditioned on notification to the taxpayer under the law; (2) petitioner’s argument in her petition to the Tax Court, that the “penalty for at least three years should also be removed”, was not raised in petitioner’s Request for a Collection Due Process Hearing or during the hearing itself, and it cannot be raised for the first time in this Court; and (3) the settlement officer’s rejection of petitioner’s offer in compromise was not raised in her petition to this Court, and is therefore deemed conceded under Rule 331(b)(4). III. Receipt of Lien Notice Respondent first argues that even if petitioner did not receive the lien notice, she timely submitted a Form 12153, she was given a Collection Due Process Hearing to satisfy the requirements under section 6320 and section 6330, and the validity and priority of the Government’s lien is not conditioned on notification to the taxpayer under the law. Section 6321 imposes a lien in favor of the United States upon all property and rights to property of a taxpayer where there exists a failure to pay any tax liability after demand for payment. Within 5 business days after filing notice of a lien pursuant to section 6323, the Secretary must notify the taxpayerPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011