Dina DeSalvo - Page 7

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          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 taxpayer            






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