- 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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