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rely merely on allegations or denials in the pleadings. Grant
Creek Water Works, Ltd. v. Commissioner, 91 T.C. 322, 325 (1988);
Casanova Co. v. Commissioner, 87 T.C. 214, 217 (1986).
Section 6321 creates a lien in favor of the United States on
all property and rights to property belonging to a person liable
for taxes when payment has been demanded and neglected. The lien
arises by operation of law when the Internal Revenue Service
(IRS) assesses the amount of unpaid tax. Sec. 6322. The IRS
files a Notice of Federal Tax Lien to preserve priority and put
other creditors on notice. See sec. 6323.
Section 6320 provides that the Secretary shall furnish the
person described in section 6321 with written notice of the
filing of a lien under section 6323. This notice must be
provided not more than 5 business days after the day the notice
of lien is filed and must advise the taxpayer of the opportunity
for administrative review in the form of a hearing. Sec.
6320(a)(2). Sec. 6320 further provides that the taxpayer may
request a hearing within the 30-day period beginning on the day
after the 5-day period. The hearing generally shall be conducted
consistent with the procedures set forth in section 6330(c), (d),
and (e). Sec. 6320(c).
A taxpayer may raise any relevant issue at the hearing,
including challenges to “the appropriateness of collection
actions” and may make “offers of collection alternatives, which
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Last modified: November 10, 2007