Dina DeSalvo - Page 8

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          of her right to a fair hearing before an impartial Appeals                  
          officer, generally to be conducted in accordance with the                   
          procedures described in section 6330(c), (d), and (e).  Sec.                
          6320.                                                                       
               Before proceeding with a lien, the Secretary must meet                 
          several notice requirements.  Section 6320(a)(1) provides that              
          the Secretary shall notify in writing the taxpayer described in             
          section 6321 of the filing of a notice of lien under section                
          6323.  Section 6320(a)(2) specifies that such notice be:  (1)               
          Given in person; (2) left at the taxpayer’s dwelling or usual               
          place of business; or (3) sent by certified or registered mail to           
          the taxpayer’s last known address.  Further, such notice must be            
          furnished not more than 5 business days after the day of the                
          filing of the notice of lien.  See id.                                      
               Section 301.6320-1, Proced. & Admin. Regs., addresses the              
          consequences of a taxpayer’s not receiving or accepting a                   
          Collection Due Process Notice (CDP Notice) that is properly sent            
          by certified mail to the taxpayer’s last known address.  Section            
          301.6320-1(a)(2), Q&A-11, Proced. & Admin. Regs., provides:                 
                    A CDP Notice properly sent by certified or registered             
                    mail to the taxpayer’s last known address * * * is                
                    sufficient to start the 30-day period, commencing the             
                    day after the end of the five business day notification           
                    period, within which the taxpayer may request a CDP               
                    hearing.  Actual receipt is not a prerequisite to the             
                    validity of the CDP Notice.                                       








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