Segudino and Delfa Razo - Page 4

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          would impede their ability to earn greater income in the future,            
          or pay off their existing debts in an installment agreement.  Mr.           
          Razo is 62 years old and is employed as a manual laborer.  Mrs.             
          Razo is unemployed due to health problems.  In addition, the                
          Appeals officer noted that petitioners are currently in arrears             
          on their mortgage and car payments, and they owe significant                
          amounts of real estate taxes.  The Appeals officer recommended              
          that petitioners’ account be suspended as “temporarily not                  
          collectible”.  By suspending their account as “temporarily not              
          collectible”, the Appeals officer halted collection activity                
          until petitioners’ financial situation changes and either payment           
          is forthcoming or another collection alternative is feasible.               
          The determination would allow the Government to recover a portion           
          of any proceeds from a future sale or foreclosure on any of                 
          petitioners’ assets.  The Appeals officer concluded that although           
          it was unlikely that petitioners would be able to pay their                 
          liabilities other than from the value of their assets, the lien             
          would enable the Government to preserve its priority rights in              
          any foreclosure or bankruptcy proceedings.   Petitioners timely             
          filed a petition with this Court for review of the Appeals                  
          officer’s determination.                                                    
          Discussion                                                                  
               Sections 6320 (pertaining to liens) and 6330 (pertaining to            
          levies) were enacted as part of the Internal Revenue Service                






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