Kathryn D. Mills - Page 8

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                       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.                               






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