49, 60, n.7 (1999), that an expectancy would not constitute "property" for the purposes of a
federal tax lien. But Drye's discussion of an "expectancy" did not decide the issue for the Craft court.
Since the OIC and supporting documentation had not arrived by March 14, when the SO closed the file, or by March 21, when the IRS mailed the notice of determination, the IRS on those dates had before it no basis for compromising Sze-kely's tax liabilities and thus no basis for disturbing the notice of
federal tax lien.
A
federal tax lien is filed in the office designated by the state where any real property owned by the taxpayer is located (Sec.
1962) and Note 30.02.01 of ATTORNEYS TITLE INSURANCE FUND, INC.: FUND TITLE NOTES (A
federal tax lien can be enforced against homestead property); Busby v.
A Notice of
Federal Tax Lien will probably be filed to protect the Government's claim during the suspension period.
To have the NFTL withdrawn from the record, the taxpayer must apply and qualify for an NFTL withdrawal by filing IRS Form 12277, Application for the Withdrawal of Filed Form 668(Y), Notice of
Federal Tax Lien. IRC section 6323[R] provides four statutory conditions in which a withdrawal is appropriate:
CAP is available for taxpayers in the following situations: (1) before or after the IRS files a Notice of
Federal Tax Lien or levies or seizes property, (2) if the IRS has terminated or proposed to terminate an installment agreement, rejected an installment agreement, or modified or proposed to modify an installment agreement (IRS Publication 1660, Collection Appeal Rights (2012)).
The 45-year-old was also said to be a repeat tax offender after another
federal tax lien reported that he owed more money from three more years of unpaid debts.
Once the notice of
federal tax lien is filed, the taxing authority is not prejudiced by successive bankruptcies, unless the debtors have assets available to the taxing authority, either acquired prior to or during the interim pendency of successive bankruptcies.
Seller, Internal Revenue Service; byer, Carney Oil Field Sales and Service LLC;
Federal Tax Lien.
A Notice of
Federal Tax Lien may be filed on a taxpayer's real or personal property under Sec.
If the responsible person dies after the assessment but before the penalty is paid, the Tax Court held, a notice of
federal tax lien filed shortly after the taxpayer's death is valid.