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Tax Seminar #3 – December 3 2012

Workbook - Zicklin School of Business

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Notice and Demand of <strong>Tax</strong> Due<br />

• The “ Notice and Demand” triggers three key<br />

consequences:<br />

1. Lien arises in favor of the IRS. IRC §§ 6321, 6331<br />

2. IRS is permitted to use administrative collection<br />

measures including levy.<br />

3. Failure to pay penalty will accrue from the date of the<br />

notice and demand unless the assessed amount is paid<br />

within 21 days. IRC § 6651(a)(3).<br />

5<br />

Payment of <strong>Tax</strong>es<br />

• If the taxpayer can pay after receipt of the<br />

notice and demand, he or she should do so.<br />

Paying will avoid the late payment penalties<br />

from accruing, will avoid further interest<br />

accrual and will avoid the taxpayer being<br />

subject to liens and levies.<br />

6<br />

185

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