Crevenne C. and Barbara A. Carrillo - Page 12

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               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 forth                 






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