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entitled to judgment as a matter of law. Sundstrand Corp. v.
Commissioner, 98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th
Cir. 1994). Facts are viewed in the light most favorable to the
nonmoving party. Id. However, where a motion for summary
judgment has been properly made and supported by the moving
party, the opposing party may not rest upon mere allegations or
denials contained in that party’s pleadings but must by
affidavits or otherwise set forth specific facts showing that
there is a genuine issue for trial. Rule 121(d). The Court has
considered the pleadings and other materials in the record and
concludes that there is no genuine justiciable issue of material
fact regarding the collection matters in this case.
Section 6321 imposes a lien in favor of the United States
upon all property and rights to property of a person where there
exists a failure to pay any tax liability after demand for
payment. The lien generally arises when the assessment is made.
Sec. 6322.
Section 6320 entitles a person to notice of her right to
request a hearing after a notice of lien is filed by the
Commissioner in furtherance of the collection from the person of
unpaid Federal taxes. If one is requested, the administrative
hearing is before the Appeals Office of the Internal Revenue
Service. Sec. 6320(b)(1). The person requesting the hearing may
raise any relevant issue with regard to the Commissioner’s
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