A taxpayer successfully challenged the IRS?s filing of a notice of federal tax lien against him for a trust fund recovery penalty on the basis that he did not have an opportunity to contest the liability on which the assessment underlying the lien was based.
Source: http://feedproxy.google.com/~r/AICPA_TaxAdvisor/~3/KSOO0xHQHA4/20130531.aspx
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