Tag Archive for Notice Of Federal Tax Lien

TEFRA Audits, IRS Taxes And Penalties, Notice Of Federal Tax Lien, And Collection Due Process Hearing

TEFRA Audits, IRS Taxes And Penalties, Notice Of Federal Tax Lien And Collection Due Process Hearing

Goldberg v. Comm’r, T.C. Memo. 2021-119 | October 19, 2021 | Paris, J. | Dkt. No. 12871-18L

Short Summary:  Mr. Goldberg was an investor and partner in two oil and gas partnerships.  The two partnerships were subject to TEFRA audits, and the IRS timely assessed taxes and penalties related to the TEFRA audits against Mr. Goldberg.  Later, the IRS issued notices of federal tax lien (NFTL) with respect to the taxes and penalties.  Mr. Goldberg failed to timely challenge the NFTL.  Later, after the IRS issued a notice of intent to levy, Mr. Goldberg timely filed a request for a Collection Due Process (CDP) hearing.  During the CDP hearing, Mr. Goldberg challenged the amount of taxes and penalties that he owed.

Key Issues:

  • Whether Mr. Goldberg is prohibited from challenging his underlying tax liabilities in the CDP hearing?

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Written by | Posted in IRS Penalty • TEFRA Audits

When Will The IRS Withdraw A Notice Of Federal Tax Lien?

Venar Ayar - When Will The IRS Withdraw A Notice Of Federal Tax Lien.
What Is The Difference Between A Federal Tax Lien And A Notice Of Federal Tax Lien?

There’s an important distinction between the federal tax lien and the Notice of Federal Tax Lien. The federal tax lien automatically applies to all of your property when you fail to pay taxes after a demand for payment. The Notice of Federal Tax Lien is an official record that gives the public notice of the lien.

The Notice of Federal Lien needs to be filed with state or local authorities, such as the country recorder of deeds. When the IRS removes the notice from public records, it is referred to as a “withdrawal.”

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Written by | Posted in Notice Of Federal Tax Lien