Mark Lewis Tracton - Page 7




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          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 the Secretary must send a                   
          taxpayer written notice of the filing of a notice of Federal tax            
          lien under section 6323.  The notice required by section 6320               
          must be provided not more than 5 business days after the filing             
          of the notice of lien.  Sec. 6320(a)(2).  Section 6320 further              
          provides that the person may request administration review of the           
          matter (in the form of an Appeals Office hearing) within 30 days            
          beginning on the day after the 5-day period.  An administrative             
          hearing under section 6320 is conducted in accordance with the              
          procedural requirements of section 6330.  Sec. 6320(c).                     
               Section 6330(c)(2) prescribes the matters that a person may            
          raise at an Appeals Office hearing.  Under that section, a person           
          may raise any relevant issue relating to the unpaid tax,                    
          including a spousal defense or collection alternatives.  Sec.               
          6330(b) and (c)(2); sec. 301.6320-1(e)(1), Proced. & Admin. Regs.           
          A challenge to the existence or amount of the underlying tax                
          liability may also be made, but only if the taxpayer did not                
          receive any statutory notice of deficiency for such tax liability           
          or did not otherwise have an opportunity to dispute such tax                








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