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Tax Court denies jurisdiction on underlying tax liability.

Publication: The Tax Adviser
Publication Date: 01-OCT-02 		Format: Online - approximately 877 words
Delivery: Immediate Online Access

Article Excerpt
In Behling, 118 TC No. 36 (2002), the Tax Court ruled that even though an Appeals Officer considered a taxpayer's underlying tax liability in a collection-due-process hearing, the taxpayer was barred from raising the issue in Tax Court, because he had received a deficiency notice. Behling is one of several recent Tax Court decisions interpreting Secs. 6320 and 6330, which Congress enacted in 1998 to provide due-process protections to taxpayers from IRS lien and levy actions.

Background

Sec. 6321 imposes a lien on all of a taxpayer's property and rights to property when demand for payment has been made and the taxpayer has not paid the taxes due. Under Sec. 6322, a lien arises when an assessment is made. For the lien to be valid against other parties, a lien...

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