Notice of Federal Tax Lien only after making an assessment, sending a Notice and Demand for Payment and remaining unpaid.

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The expatriate will have to petition the U.S. Tax Court to prevent the notice of deficiency from becoming a final assessment.

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"When a public-sector union imposes a special assessment of dues increase, the union must provide a fresh ... notice and may not exact any funds from nonunion members without their affirmative consent, " Alito added.

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