Hailu Yohannes Awlachew - Page 9




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          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 may                  







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