James Weldon Aaron - Page 6

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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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