- 12 - raised yet, or if other issues that you have not raised yet, but for which you believe are legitimate--although read my order, and I told you what I think on the ones that I have seen to date--then you should raise them here. Mr. Carrillo, however, proceeded to rehash matters relied upon in petitioners’ earlier papers and filings and failed to identify any specific colorable issues for remand. The only potentially novel issue cited was that of a February 11, 2003, notice of levy issued to petitioners’ bank, as to which see supra note 4. The parties subsequently filed posttrial briefs. Petitioners recapitulated the positions taken throughout these proceedings and at trial, including focusing once again on lack of a recorded hearing. OPINION I. Collection Actions A. General Rules Section 6321 imposes a lien in favor of the United States upon all property and rights to property of a taxpayer liable for tax where there exists a failure to pay the tax liability after demand for payment. The lien generally arises at the time assessment is made. Sec. 6322. Section 6323, however, provides that such lien shall not be valid against any purchaser, holder of a security interest, mechanic’s lienor, or judgment lien creditor until the Secretary files a notice of lien with the appropriate public officials. Section 6320 then sets forthPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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