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property and rights to property belonging to such person.2
Section 6320(a)(1) provides that the Secretary shall notify
persons described in section 6321 of the filing of a notice of
lien.3 Section 6320(a)(3) provides that such notification shall
inform the person in simple and nontechnical terms of (1) the
amount of the unpaid tax, (2) the right of the person to request
a hearing before an impartial officer of the Commissioner’s
Appeals Office, (3) the administrative appeals available to the
taxpayer, and (4) the provisions relating to the release of liens
on property.4
2SEC. 6321. Lien for Taxes.--
If any person liable to pay any tax neglects or refuses to
pay the same after demand, the amount (including any interest,
additional amount, addition to tax, or assessable penalty,
together with any costs that may accrue in addition thereto)
shall be a lien in favor of the United States upon all property
and rights to property, whether real or personal, belonging to
such person.
3SEC. 6320(a). Requirement of Notice.--
(1) In General.--The Secretary shall notify in writing
the person described in section 6321 of the filing of a
notice of lien under section 6323.
4SEC. 6320(a). Requirement of Notice.--
(3) Information included with notice.--The notice
required under paragraph (1) shall include in simple and
nontechnical terms--
(A) the amount of the unpaid tax;
(B) the right of the person to request a hearing
during the 30-day period beginning on the day after the
(continued...)
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Last modified: May 25, 2011