Estate of Bonnie W. Deese, Deceased, Gladys Deese, Personal Representative - Page 4




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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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