- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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