CHARLES EDWIN LYKES - Page 6

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                                       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 the taxpayer, in writing, that a            
          tax lien was filed and inform the taxpayer of his/her right to a            
          hearing before an impartial Appeals officer.  Sec. 6320.                    
          Pursuant to section 6320(c), the hearing is to be conducted                 
          consistent with procedures set forth in subsections (c), (d)                
          (other than paragraph (2)(B) thereof), and (e) of section 6330.             
          If the Commissioner issues a determination letter adverse to the            
          position of the taxpayer, the taxpayer may seek judicial review             
          of that determination.  Sec. 6330(d).                                       
               Preliminarily we deal with a jurisdictional issue.                     
          Petitioner maintains that we should consider his income and                 
          employment tax liabilities together because the assigned IRS                
          revenue officer pursued the collection of petitioner’s income tax           
          liabilities in conjunction with his employment tax liabilities.             
          Respondent, on the other hand, objects to petitioner’s raising of           
          respondent’s collection activities of petitioner’s employment tax           
          liability.  Respondent maintains that the lien in question                  
          pertains only to petitioner’s unpaid income taxes for 1996-99,              
          not petitioner’s unpaid employment taxes.  In this regard,                  






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