Investment Research Associates, Inc. - Page 5

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          The decision letter stated that the Appeals Office rejected                 
          petitioner’s offer-in-compromise and that the liens were properly           
          filed and would not be released.                                            
              On September 2, 2005, petitioner filed with the Court a                
          petition for lien or levy action challenging respondent’s                   
          decision letter.  Petitioner acknowledged in its petition that              
          respondent filed the Florida lien in October 2002 and that                  
          respondent issued to petitioner a Notice of Federal Tax Lien                
          Filing at that time.  The petition states that petitioner did not           
          submit to respondent a request for an administrative hearing                
          after receiving notice of the Florida lien because petitioner did           
          not own significant assets in the State of Florida.                         
               The Court issued an order in this case directing the parties           
          to show cause why this case should not be dismissed for lack of             
          jurisdiction.  Both parties filed responses to the Court’s order.           
          The Court subsequently directed respondent to file a reply to               
          petitioner’s response, and respondent complied with the Court’s             
          order.                                                                      
                                   Discussion                                         
               Section 6321 imposes a lien in favor of the United States on           
          all property and rights to property of a person liable for tax              
          when a demand for the payment of the person’s taxes has been made           
          and the person fails to pay those taxes.  Such a lien arises when           
          an assessment is made.  Sec. 6322.  Section 6323(a) requires the            






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