- 8 - * * * * * * * Relevant Issues Raised by the Taxpayer On Form 12153, you raised several issues including that you had an offer in compromise on file, there was an improper determination of collection value, and finan- cial hardship--impairment of employment. At your collection due process hearing you explained the events, which caused the liability. Alternatives to the lien were reviewed such as posting a bond, substitution of collateral, or full payment of the account. None of these options are available to you at this time. Balancing Efficient Collection with the intrusiveness of the Collection Action You have produced no evidence that indicates that the withdrawal of the Notice of Federal Tax Lien would facilitate collection of the liability, or that any of the other grounds for withdrawal under IRC section 6323(j) are applicable. You have offered no collection alternatives that would permit the release of the lien. A withdrawal of the lien would create a detriment to the government’s position. Thus, absent some statutory basis to withdraw the Notice of Federal Tax Lien, or release the lien, maintaining the filed lien balances the need for the efficient collection of taxes with your legitimate concern that any collection action be no more intrusive than necessary. In the petition that she filed in this case, petitioner alleged: The relief requested is that the IRS should release a federal tax lien that the IRS has filed against the taxpayer. The reasons for such relief are that the IRS abused its discretion in failing to consider the infor- mation that the taxpayer submitted to support its offer in compromise, there was an improper determination of collection value, and the taxpayer’s financial hardship-impairment of employment. A withdrawal of the lien would facilitate collection action.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011