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procedures applicable to afford protections for taxpayers in lien
situations.
Section 6320(a)(1) establishes the requirement that the
Secretary notify in writing the person described in section 6321
of the filing of a notice of lien under section 6323. This
notice required by section 6320 must be sent not more than 5
business days after the notice of tax lien is filed and must
advise the taxpayer of the opportunity for administrative review
of the matter in the form of a hearing before the IRS 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).
Likewise, section 6331(a) authorizes the Commissioner to
levy upon all property and rights to property of a taxpayer where
there exists a failure to pay any tax liability within 10 days
after notice and demand for payment. Sections 6331(d) and 6330
then specify germane protective procedures. Section 6331(d)
generally requires that a person be provided with at least 30
days’ prior written notice of the Commissioner’s intent to levy
before collection may proceed. Section 6331(d) also indicates
that this notification should include a statement of available
administrative appeals. Section 6330(a) expands in several
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