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petitioner had received the Form 4340, Certificate of
Assessments, Payments and Other Specified Matters, which he had
sent to petitioner. Petitioner replied that he had. Appeals
Officer Kelly then asked whether petitioner had any collection
alternatives to the tax lien. Petitioner did not respond to
Appeals Officer Kelly’s question. Rather, Ms. Zapert asserted
that petitioner had been denied a meeting with Appeals before the
notice of deficiency was issued. Bickering between Ms. Zapert
and Appeals Officer Kelly ensued, and the meeting was terminated
shortly thereafter. Petitioner never offered any collection
alternatives during the meeting.
On March 1, 2002, 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 has been made.
Within 5 business days after the day of filing the notice of
lien, the Secretary must notify in writing the person against
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