I. Federal Tax Liens

    The federal tax lien arises once there has been an assessment, demand has been made and the taxpayer has failed to pay.

    As discussed below, the reach of the federal tax lien under IRC Section 6321 is very broad, reaching all of the taxpayer's property and rights to property, including after-acquired property.  When a taxpayer's property in not in the hands or name of the taxpayer, or where the taxpayer has transferred property, the Internal Revenue Service (the "Service") has used a number of theories to reach the property including:  nominee, alter-ego, fraudulent conveyance, and transferee liability.

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*Dennis Brager, Esq., is a State Bar Certified Tax Specialist in Los Angeles. A former IRS senior trial attorney, Mr. Brager now devotes his efforts exclusively to helping clients resolve their tax problems with the IRS and California State tax agencies. Services include negotiating Tax Debts, Tax Fraud Representation, Tax Litigation, Tax Audit and Appeals Representation,  Tax Preparer Penalty Mitigation, Payroll Tax Audits, and California Sales Tax Problems. He may be reached at 800.380.TAX LITIGATOR.