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officer suggested an installment agreement because petitioner
lacked liquid assets with which to pay his tax liabilities.
Petitioner was not willing to enter into an installment
agreement; instead, he wanted to discharge his liabilities
through a lump-sum payment as part of an OIC.
Petitioner and the settlement officer spoke by telephone in
the weeks following the face-to-face hearing. The settlement
officer sent petitioner a proposed installment agreement that
called for monthly payments of $140 until petitioner’s
liabilities were paid in full. Petitioner did not sign the
proposed installment agreement. On July 12, 2004, respondent
issued a notice of determination to petitioner sustaining the
filing of the notice of Federal tax lien. The notice of
determination states that the “requirements of various applicable
legal and administrative procedures have been met”. It also
states that the notice of Federal tax lien was filed “since the
unpaid balance of assessment was $5,000 or more [Internal Revenue
Manual 5.12.1.13-Filing Guidelines]”.
Discussion
Section 6321 imposes a lien in favor of the United States on
all property and rights to property of a person when a demand for
the payment of the person’s liability for taxes has been made and
3(...continued)
The discrepancy has not been explained.
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