By Eric K. Fox, Esq. (Hendersonville, TN) Jane Debtor has a home with a mortgage. An unsecured creditor obtains a judgment against Jane for, say, a credit card debt. Creditor’s attorney records a certified copy of the judgement order with the county register of deeds, thereby converting the unsecured claim against Jane in personam, to a secured claim against her...
Holding: IRS Did Not Abuse Its Discretion in Denying Debtor’s Offer-In-Compromise While Bankruptcy Case Was Pending
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By Morgan D. King, Esq. Dublin, CA
Salazar v. Commissioner of Internal Revenue, T.C. Memo. 2008-38 (U.S.T.C., 2008)
As respondent's counsel now explains, an offer-in-compromise must include all of the outstanding liabilities of the taxpayer. Further, section 6325(a) provides that the Commissioner "shall issue a certificate of release of any lien imposed with respect to any internal revenue tax" not later than 30 days after the liability for the amount has been fully satisfied.
Thus respondent argues, if respondent were to accept an offer-in-compromise and . . .
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