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outstanding liabilities for 1993 and 1997. Petitioners timely
filed a petition seeking review of the determination.5
Discussion
Section 6321 imposes a lien in favor of the United States on
all property and rights to property of any person who fails to
pay a tax after demand. Such a lien arises when an assessment is
made and generally becomes effective against third parties upon
the filing of notice thereof by the Secretary. Secs. 6322 and
6323. Section 6320 provides that the Secretary shall furnish the
person described in section 6321 (taxpayer) with written notice
of the filing of a lien under section 6323 not more than 5
business days after the day of filing the notice. Section 6320
further provides that the taxpayer 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. Sec.
6320(a)(3)(B), (b)(1). Section 6320(c) provides that the Appeals
Office hearing shall be conducted consistent with the procedures
set forth in subsections (c), (d), and (e) of section 6330.
Section 6330(c)(1) provides that the Appeals officer shall
verify that the requirements of any applicable law or
5 The petition sought review of taxable years 1991, 1992,
1993, and 1997 (but not 1994). On July 2, 2003, we granted
respondent's motion to dismiss for lack of jurisdiction with
respect to taxable years 1991 and 1992, as no notice of
determination to proceed with a collection action had been issued
with respect to those periods.
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