- 3 - Respondent issued petitioner the notice of determination on February 23, 2005, sustaining the filing of the Federal tax lien. The notice of determination states that petitioner could not challenge the levy on his Social Security benefits because it did not relate to the years at issue. The notice also states that respondent placed petitioner’s accounts in “Currently not Collectible status and no further collection action would take place.” Discussion Section 6321 imposes a lien in favor of the United States on all property and rights to property of a person when a demand for the payment of the person’s liability for taxes has been made and the person fails to pay those taxes. Such a lien arises when an assessment is made. Sec. 6322. Section 6323(a) requires the Secretary to file a notice of Federal tax lien if the lien is to be valid against any purchaser, holder of a security interest, mechanic’s lienor, or judgment lien creditor. Lindsay v. Commissioner, T.C. Memo. 2001-285, affd. 56 Fed. Appx. 800 (9th Cir. 2003). Section 6320 provides that a taxpayer shall be notified in writing by the Secretary of the filing of a notice of Federal tax lien and provided with an opportunity for an administrative hearing. An administrative hearing under section 6320 is conducted in accordance with the procedural requirements ofPage: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007