- 4 -
1997 with his letter. In his letter, Appeals Officer Kelly
stated that the tax petitioner reported when he filed his tax
return is the tax owed and that the amended tax returns are not
valid.
A telephone hearing was held as scheduled. During that
hearing petitioner advanced tax-protester arguments regarding his
tax obligation and respondent’s filing of the Federal tax lien.
Petitioner did not raise any relevant issues relating to the
existence or amount of his unpaid taxes. Nor did petitioner make
any offers of collection alternatives.
On November 2, 2001, a Notice of Determination Concerning
Collection Action Under Section 6320 (Lien) of the Internal
Revenue Code was sent to petitioner. In that notice, respondent
determined that the filing of a Federal tax lien was an
appropriate collection action. Petitioner then filed a petition
with this Court under section 6330(d) disputing respondent’s
determination. See sec. 6320(c).
OPINION
Section 6321 imposes a lien in favor of the United States
upon all property and rights to property belonging to a person
liable for unpaid taxes after demand for payment. Within 5
business days after the day of filing the notice of lien, the
Secretary must notify in writing the person against whom the lien
is filed (the taxpayer) that a tax lien was filed and inform the
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