Investment Research Associates, Inc. - Page 11

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               E.  Analysis                                                           
               Section 6320(a)(1) requires the Commissioner to give written           
          notice to a taxpayer when a Federal tax lien is filed under                 
          section 6323.  Given that section 6323(f)(1) contemplates the               
          filing of separate liens in multiple States, or in multiple                 
          counties or other governmental subdivisions within a State, it              
          follows that a taxpayer (like petitioner in the present case) may           
          receive multiple lien notices under section 6320(a)(1).  Although           
          a person may receive multiple lien notices under section                    
          6320(a)(1), section 6320(b)(2) clearly states that the person is            
          entitled to only one administrative hearing under section 6320              
          with respect to the unpaid tax for a particular taxable period              
          for which a lien was filed.  The statute does not, however,                 
          explicitly address the narrow question presented in this case;              
          i.e., whether a taxpayer’s right to an administrative hearing in            
          the Appeals Office and judicial review of the Appeals Office’s              
          determination is tied to the first Federal tax lien filed against           
          the taxpayer or whether the taxpayer may defer and request an               
          administrative hearing in respect of a later filed lien.                    
               As noted earlier, respondent relies on section 301.6320-1(b)           
          (1) and (2), Proced. & Admin. Regs., as authority for the                   
          proposition that a taxpayer must request an administrative                  
          hearing with respect to the first Federal tax lien that is filed            
          in respect of unpaid tax for a particular taxable period.                   






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