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7) The Settlement Officer in your case has had
no prior involvement with you concerning the
tax periods at issue in this due process
hearing, pursuant to requirements of Internal
Revenue Code Section 6330.
ISSUES RAISED BY THE TAXPAYER
1) that you should be given opportunity to work
out a fair payment plan or settlement, since you
were unable to pay the taxes in full.
Finding: Collection alternatives were considered,
including an Installment Agreement and an Offer-
in-Compromise. Your current limited income does
not allow you to fund an acceptable Installment
Agreement. Your Offer-in-Compromise could not be
accepted because you have more equity in assets
than the amount of the tax due.
2) No other substantive issues were raised.
BALANCING THE NEED FOR EFFECTIVE COLLECTION OF THE TAX
WITH LEGITIMATE TAXPAYER CONCERN THAT COLLECTION AC-
TIONS BE NO MORE INTRUSIVE THAN NECESSARY
Filing of the Notice of Federal Tax Lien was clearly
intrusive, and has far-reaching adverse financial
consequences, since it puts other creditors on notice
of your federal tax debt, and creates difficulties with
borrowing funds that may be necessary to provide for
basic health and welfare of the family, or production
of income.
Therefore, it is the policy of the Internal Revenue
Service to provide taxpayers ample opportunity to
resolve their tax matters before a Notice of Federal
Tax Lien is filed, although a lien may be filed at any
time it is deemed necessary to protect the government’s
interest.
The case file reveals that Internal Revenue Service had
multiple personal contacts with you concerning your
delinquent taxes, but that such efforts did not result
in a mutually agreeable resolution to your tax problem.
Therefore, lien filing was deemed necessary.
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Last modified: November 10, 2007