- 6 - 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“provided no concrete information as to how the collection would be facilitated” if the notice of Federal tax lien were withdrawn, respondent determined the Federal tax lien should not be withdrawn.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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007