Chief Counsel's Position is Use of UPS to Deliver Notice of Non-Judicial Sale Did Not Satisfy IRC Requirements, IRS Lien Remains Intact

In Chief Counsel Email 201545025 the issue involved whether the use of an approved private delivery service was acceptable for delivery to the IRS of notices of non-judicial sales.

IRC §7425 deals with the IRS’s rights when the service obtains a lien on property.  Generally such a lien is not impacted by any judicial proceeding to which the IRS is not a party.  A limited exception occurs in certain cases described in IRC §7425(b) if the IRS is properly notified of the proceeding.

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