- 6 - 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 taxPage: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007