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respondent determined petitioners were liable for an addition to
tax under section 6651(a)(2) because they did not establish that
their failure to pay the tax shown on their return was due to
reasonable cause.3 Respondent also determined petitioners were
not entitled to an abatement of interest. Because petitioners
“provided no concrete information as to how the collection would
be facilitated” if the notice of Federal tax lien were withdrawn,
respondent determined the Federal tax lien should not be
withdrawn. Respondent verified that all statutory and
administrative requirements were met and concluded that the
filing of the notice of Federal tax lien was appropriate.
In response to the notice of determination, petitioners
filed a petition with this Court on August 8, 2005.
OPINION
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
3 Because respondent found petitioners were not liable for
the addition to tax under sec. 6651(a)(1), respondent increased
the amount of the addition to tax under sec. 6651(a)(2) by $4,725
to $6,620.
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Last modified: November 10, 2007