Albert M. Kun - Page 4

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          circumstances were present “such that collection of the full                
          liability will be detrimental to voluntary compliance”, and there           
          was no evidence that a compromise would encourage future                    
          compliance and promote effective tax administration.                        
               4.  Petitioner declined to consider an installment                     
          agreement.                                                                  
               5.  The notice of Federal tax lien filing balanced the need            
          for efficient collection of taxes with the legitimate concern of            
          the taxpayer that the collection action be no more intrusive than           
          necessary.                                                                  
               On October 30, 2002, petitioner filed a timely petition                
          contesting respondent’s determination.  Petitioner alleged that             
          “the Internal Revenue Service abused its discretion in making the           
          findings and conclusions it did and abused its discretion in                
          rejecting petitioner’s offer in compromise.”                                
                                       OPINION                                        
               All property and rights to property of a taxpayer become               
          subject to a lien in favor of the United States on the date a tax           
          liability is assessed against the taxpayer if the taxpayer fails            
          to meet the Commissioner’s demand for payment of the tax                    
          liability.  Secs. 6321 and 6322.  Until a notice of Federal tax             
          lien is filed, a lien is without validity and priority against              
          certain persons such as judgment lien creditors of the taxpayer.            
          Sec. 6323(a).  After the Secretary files the notice of Federal              






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