- 4 - respondent’s motion for summary judgment by October 3, 2007. The Court has received no response. Discussion Summary judgment may be granted where there is no genuine issue of any material fact, and a decision may be rendered as a matter of law. Rule 121(a) and (b); see Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994); Zaentz v. Commissioner, 90 T.C. 753, 754 (1988). When a motion for summary judgment is made and properly supported, the adverse party may not rest upon mere allegations or denials of the pleadings but must set forth specific facts showing that there is a genuine issue for trial. Rule 121(d). If appropriate, a decision may be entered against a party who fails to respond to a motion for summary judgment. Id. Section 6321 imposes a lien in favor of the United States on all property and property rights of a person who is liable for and fails to pay tax after demand for payment has been made. For the lien to be valid against certain third parties, the Secretary must file a notice of Federal tax lien; within 5 business days thereafter, the Secretary must provide written notice to the person against whom the lien is filed. Secs. 6320(a), 6323(a). Within 30 days commencing the day after the end of the 5 business days, the person may request an administrative hearing before anPage: Previous 1 2 3 4 5 6 7 NextLast modified: March 27, 2008