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expenses in the future. Petitioner requested that respondent
dismiss or forgive her unpaid tax liability.
By letter dated April 6, 2004, respondent contacted
petitioner to discuss the stipulation of facts for petitioner’s
trial, scheduled for April 26, 2004. Respondent wrote: “I have
also not ruled out the possibility of an offer in compromise, but
I will need more information. I have enclosed an IRS form 433-
A.1 I would like you to fill this out as soon as possible.”
On April 8, 2004, petitioner faxed to respondent a completed
Form 433-A. On the Form 433-A, petitioner listed personal assets
including a bank account with a balance of $134,198, other
security investments including “United States HHH Bonds”, and a
home that she owns clear of any encumbrances.
Discussion
Section 6321 imposes a lien in favor of the United States
upon all property and rights to property of a taxpayer who fails
to pay any tax liability after demand for payment. The lien
arises when the assessment is made, but is not valid against any
purchaser, holder of a security interest, mechanic’s lienor, or
1 A Form 433-A, Collection Information Statement for Wage
Earners and Self-Employed Individuals, is used by the Internal
Revenue Service to access a taxpayer’s financial situation for
purposes of collecting unpaid tax liabilities. In completing
this form the taxpayer is required to provide information about
his or her financial assets and monthly income and expenses.
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Last modified: May 25, 2011