Provisional attachment of property can be ordered after notice and an opportunity to make submissions to protect revenue. An Assistant Commissioner or Deputy Commissioner may forward a verified proposal to the Commissioner to provisionally attach a taxpayer's property to protect revenue. The Commissioner may serve a notice stating reasons and listing property, allow the person an opportunity to make submissions within fifteen days, and, after considering submissions, may issue a written order to provisionally attach the person's property; personal property of proprietors, partners or directors is excluded.