- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: November 10, 2007