- 12 - showed that petitioner had no other debt. Petitioner, who early in the collections stage had more than $400,000 in net worth and more than $2,000 per month in disposable income, was seeking leniency for not paying taxes on his million dollar gambling winnings. Under these facts and circumstances, it was not an abuse of discretion for respondent’s settlement officer to sustain the filing of the Notice of Federal Tax Lien. We briefly address petitioner’s assignment of error that respondent erroneously filed the Notice of Federal Tax Lien. No facts in the petition indicate any basis for this assertion, but petitioner’s opposition to summary judgment reveals his view that respondent sent the notification letter late; i.e., beyond the 5- business-day period as provided in section 6320, and therefore, the lien is invalid. In support of his view, petitioner points out that the Notice of Federal Tax Lien shows the date the document was prepared and signed as May 11, 2005. According to petitioner, since the notification of the lien filing was not mailed to him until May 19, 2005, 6 business days later, the lien is invalid, and it was an abuse of discretion for respondent to sustain the lien filing. We disagree that May 11, the date the lien notice was prepared and signed, has any consequence in this case. The notice of lien sent to petitioner, the statement of the Appeals officer, and the Appeals Case Memorandum referral all say thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: November 10, 2007