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interest of the government not to accept your offer in
compromise.”
OPINION
I. Collection Action
A. General Rules
If a taxpayer liable to pay taxes fails to do so after
demand for payment, the tax liability becomes a lien in favor of
the United States against all of the taxpayer’s real and personal
property and rights to such property. Sec. 6321. The lien
arises at the time the assessment is made and continues until the
liability is satisfied or becomes unenforceable by reason of
lapse of time. Sec. 6322. The Secretary is obliged to notify
the taxpayer that a notice of a Federal tax lien has been filed
within 5 business days of filing and of the administrative
appeals available to the taxpayer. Sec. 6320(a). Upon timely
request a taxpayer is entitled to a hearing before the Internal
Revenue Service Office of Appeals regarding the propriety of the
filing of the lien. This hearing is conducted in accordance with
the procedural requirements of section 6330. Sec. 6320(b) and
(c).
The taxpayer is entitled to appeal the determination of the
Appeals Office, made on or before October 16, 2006, to the Tax
Court or a U.S. District Court, depending on the type of tax at
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Last modified: May 25, 2011