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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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Last modified: May 25, 2011