IRS Thinking on FOBD Liens
Date
2002-02-01
Authors
Harl, Neil
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Abstract
The inadequacies of the lien provision in the family-owned business deduction statute are prompting a series of IRS pronouncements on how to perfect a lien under the statute. A major issue is how to perfect the IRS lien if real estate values are not sufficient to secure the government’s claim in the event of recapture of tax benefits.