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his petition with this Court, seeking review of respondent’s
determination, on February 10, 2005. This case was submitted
fully stipulated pursuant to Rule 122 on December 14, 2005.7
Discussion
Section 6321 imposes a lien in favor of the United States on
all property and rights to property of a taxpayer liable for
taxes when a demand for payment of the taxes has been made and
the taxpayer fails to pay those taxes. Section 6320(a) provides
that the Secretary shall furnish the taxpayer with written notice
of a Federal tax lien within 5 business days after the notice of
lien is filed. Section 6320 further provides that the taxpayer
may request an Appeals hearing within 30 days beginning on the
day after the 5-day period described above. Sec. 6320(a)(3)(B)
and (b)(1). Section 6320(c) provides that the Appeals hearing
generally shall be conducted consistent with the procedures set
forth in section 6330.
Section 6330(c) provides for review with respect to
collection issues such as spousal defenses, the appropriateness
of the Commissioner’s proposed collection actions, and the
possibility of collection alternatives. Sec. 6330(c)(2)(A). The
taxpayer may also challenge the amount of the underlying tax
liability if the taxpayer did not receive a statutory notice of
7This matter was submitted for disposition by order of the
Chief Judge to Judge Julian I. Jacobs on Feb. 13, 2007.
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