TAX 9900 Lecture Notes - Lecture 8: Sole Proprietorship, Constructive Notice, Title Search
Document Summary
Tp owns a car dealership that he operates as a sole proprietorship. The service filed a nftl against the tp on 2/1/17. Tp"s outstanding tax liability is ,000 as of 2/1/17. X does not know about the nftl filed against tp. On 6/1/17 the irs decides to take collection action. Can the irs seize/levy against car, sell it to satisfy tp"s tax debt. If this were tp"s home, irs could seize; motor vehicles= super priority; innocent 3rd party purchaser takes , even though world under constructive notice through filing of nftl. Reason: you don"t want people who are interested in buying motor vehicles having to go, do title searches, go to secretary state in albany for purpose of car. Cars, motor vehicles, boats, trucks free and clear of nftl. If not super priority, irs able to seize car in 3rd parties hands to satisfy debt.
