- 5 -
judgment has been properly made and supported by the moving
party, the opposing party may not rest upon mere allegations or
denials contained in that party's pleadings but must by
affidavits or otherwise set forth specific facts showing that
there is a genuine issue for trial. Rule 121(d). The Court has
considered the pleadings and other materials in the record and
concludes that there is no genuine justiciable issue of material
fact regarding the collection matters in this case.
I. Collection Actions--General Rules
Section 6321 imposes a lien in favor of the United States
upon all property and rights to property of a taxpayer where
there exists a failure to pay any tax liability after demand for
payment. The lien generally arises at the time assessment is
made. Sec. 6322.
The Secretary must notify in writing the person described in
section 6321 of the filing of a notice of lien under section
6323. Sec. 6320(a)(1). The notice required by section 6320 must
advise the taxpayer of the opportunity for administrative review
of the matter in the form of a hearing before the Internal
Revenue Service Office of Appeals. Sec. 6320(a)(2) and (3).
Section 6320(b) and (c) grants a taxpayer, who so requests, the
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).
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011