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2. Petitioner
Petitioner argues that section 301.6320-1(b)(1) and (2),
Proced. & Admin. Regs., is not a reasonable interpretation of
section 6320 and is invalid. Specifically, petitioner argues
that, although section 6320(b)(2) expressly limits a taxpayer to
one hearing for a particular taxable period, section 6320 does
not contain any language requiring a taxpayer to request an
administrative hearing with respect to the first notice of
Federal tax lien filed by the Commissioner. As petitioner sees
it, if the Commissioner files multiple liens in different States
or governmental subdivisions at different times, the taxpayer may
request an administrative hearing with regard to any one of those
liens, so long as his or her request is made within the time
limit imposed under section 6320(a)(3)(B). Petitioner contends
that it is manifestly unreasonable to interpret section 6320 to
require a taxpayer to challenge a Federal tax lien that is filed
in a jurisdiction in which the taxpayer has little, if any,
property. Asserting that it timely filed its request for an
administrative hearing with regard to the Illinois lien,
petitioner maintains that the Court has jurisdiction in this case
on the ground the decision letter in dispute should be considered
a notice of determination consistent with the Court’s holding in
Craig v. Commissioner, 119 T.C. 252 (2002).
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