Denise Renee Lingwall - Page 6

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          Lien and Levy Actions                                                       
               Section 6321 imposes a lien in favor of the United States on           
          all property and rights to property of a person when a demand for           
          the payment of taxes has been made and the person fails to pay              
          those taxes.  Such a lien arises when the Commissioner makes an             
          assessment.  Sec. 6322.  The lien imposed under section 6321 is             
          not valid, however, against any purchaser, holder of a security             
          interest, mechanic’s lienor, or judgment lien creditor until the            
          Secretary has filed a notice of Federal tax lien with the                   
          appropriate authorities.  Sec. 6323(a); Behling v. Commissioner,            
          118 T.C. 572, 575 (2002).                                                   
               Section 6320 provides that the Secretary shall furnish the             
          person described in section 6321 with written notice of the                 
          filing of a Federal tax lien under section 6323.  Such notice               
          must be provided not more than 5 business days after the day of             
          the filing of the notice of lien (5-day period).  Sec.                      
          6320(a)(2).  Section 6320 further provides that the person may              
          request administrative review of the matter (in the form of an              
          Appeals Office hearing) within 30 days beginning on the day after           
          the 5-day period.  Section 6320(c) provides that the Appeals                
          Office hearing generally shall be conducted consistent with the             
          procedures set forth in section 6330(c), (d), and (e).                      

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