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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 an
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Last modified: March 27, 2008