- 9 - action not be more intrusive than necessary in light of petitioner’s circumstances. On December 19, 2005, petitioner’s petition contesting respondent’s determination was filed. The case was scheduled for trial, and a trial was held on October 23, 2006. OPINION All property and rights to property of a taxpayer become subject to a lien in favor of the United States on the date a tax liability is assessed against the taxpayer, if the taxpayer fails to meet the Commissioner’s demand for payment of the tax liability. Secs. 6321 and 6322. Until a lien notice is filed, a lien is without validity and priority against certain persons, such as judgment lien creditors of the taxpayer. Sec. 6323(a). After the Secretary files the lien notice, the Secretary must provide the taxpayer with written notice of the filing, informing the taxpayer of the right to request an administrative hearing on the matter. Sec. 6320(a)(1), (3)(B). Section 6320(c) requires that the administrative hearing be conducted pursuant to section 6330(c), (d) (other than paragraph (2)(B) thereof), and (e). At the hearing, a taxpayer may raise any relevant issue, including appropriate spousal defenses, challenges to the appropriateness of the collection action, and collection alternatives, such as an offer-in-compromise. Sec. 6330(c)(2)(A). Additionally, at a hearing, a taxpayer mayPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008