The Secretary shall notify in writing the person described in section 6321 of the filing of a notice of lien under section 6323.
The notice required under paragraph (1) shall be-
not more than 5 business days after the day of the filing of the notice of lien.
The notice required under paragraph (1) shall include in simple and nontechnical terms-
If the person requests a hearing in writing under subsection (a)(3)(B) and states the grounds for the requested hearing, such hearing shall be held by the Internal Revenue Service Independent Office of Appeals.
A person shall be entitled to only one hearing under this section with respect to the taxable period to which the unpaid tax specified in subsection (a)(3)(A) relates.
The hearing under this subsection shall be conducted by an officer or employee who has had no prior involvement with respect to the unpaid tax specified in subsection (a)(3)(A) before the first hearing under this section or section 6330. A taxpayer may waive the requirement of this paragraph.
To the extent practicable, a hearing under this section shall be held in conjunction with a hearing under section 6330.
For purposes of this section, subsections (c), (d) (other than paragraph (3)(B) thereof), (e), and (g) of section 6330 shall apply.
26 U.S.C. § 6320
REFERENCES IN TEXTSection 32101 of the FAST Act, referred to in subsec. (a)(3)(E), is section 32101 of Pub. L. 114-94 which enacted section 7345 of this title and section 2714a of Title 22, Foreign Relations and Intercourse, and amended this section and sections 6103, 6331, and 7508 of this title.
AMENDMENTS2019-Subsec. (b)(1). Pub. L. 116-25 substituted "Internal Revenue Service Independent Office of Appeals" for "Internal Revenue Service Office of Appeals".2015-Subsec. (a)(3)(E). Pub. L. 114-94 added subpar. (E).Subsec. (c). Pub. L. 114-113 substituted "(3)(B)" for "(2)(B)".2006-Subsec. (b)(1). Pub. L. 109-432, §407(c)(1), substituted "in writing under subsection (a)(3)(B) and states the grounds for the requested hearing" for "under subsection (a)(3)(B)".Subsec. (c). Pub. L. 109-432, §407(c)(2), substituted "(e), and (g)" for "and (e)".
STATUTORY NOTES AND RELATED SUBSIDIARIES
EFFECTIVE DATE OF 2006 AMENDMENT Pub. L. 109-432, div. A, title IV, §407(f), Dec. 20, 2006, 120 Stat. 2962, provided that: "The amendments made by this section [amending this section and sections 6330, 6702, and 7122 of this title] shall apply to submissions made and issues raised after the date on which the Secretary first prescribes a list under section 6702(c) of the Internal Revenue Code of 1986, as amended by subsection (a) [list prescribed Mar. 16, 2007, see I.R.S. Notice 2007-30, 2007-14, I.R.B. 883]."
EFFECTIVE DATE Pub. L. 105-206, title III, §3401(d), July 22, 1998, 112 Stat. 750, provided that: "The amendments made by this section [enacting this section and section 6330 of this title and amending section 7443A of this title] shall apply to collection actions initiated after the date which is 180 days after the date of the enactment of this Act [July 22, 1998]."
- Internal Revenue Code of 1986
- The term "Internal Revenue Code of 1986" means this title, and the term "Internal Revenue Code of 1939" means the Internal Revenue Code enacted February 10, 1939, as amended.
- The term "Secretary" means the Secretary of the Treasury or his delegate.
- The term "person" shall be construed to mean and include an individual, a trust, estate, partnership, association, company or corporation.
- The term "taxpayer" means any person subject to any internal revenue tax.