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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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Last modified: May 25, 2011