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completed Form 433-A, Collection Information Statement for Wage
Earners and Self-Employed Individuals, and signed Federal income
tax returns for 1999-2004 (which respondent's records indicated
had not been filed).
During the hearing, the only issue petitioner raised was the
existence of his underlying tax liability for 1997. He did not
propose any collection alternatives, he did not complete a Form
433-A as requested, nor did he file any delinquent income tax
returns. On June 16, 2005, a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 (lien notice
of determination) was issued to petitioner that sustained the
lien.
Petitioner timely filed his petition in the present case on
July 18, 2005. The petition alleges that the Form 1099-MISC
issued by Witness is fraudulent and that petitioner received no
income from Witness in 1997.
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. The 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
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Last modified: November 10, 2007