The United States has the power to place a lien on a taxpayers’ property and rights to property when that taxpayer has unpaid federal taxes.[1] The government is statutorily authorized to bring a civil action to enforce this lien under Internal Revenue Code (IRC) § 7403.[2] While § 7403 generally provides that courts are to adjudicate lien enforcement actions on …
Common Sense–Always use common sense when dealing with the IRS. Communication–Communicate with the taxpayer and the IRS. Ask the taxpayer and the IRS many questions. If you do not understand something, then continue asking questions. Ask many questions. Use why, what, when, etc. Prepare for the IRS–Fully develop the facts and law. Before negotiating with the IRS, make sure you …
