IRS CCA: Attach Contract Payments Satisfying Support to Federal Tax Lien (IRC §6321)

July 1, 2022, 5:00 a.m

A federal tax lien is attached to a contract containing the terms of paying a taxpayer’s child support obligation, the chief counsel’s office informally said. The taxpayer has sold three companies. The one executed contract required the monies to be paid as alimony to the taxpayer’s ex-wife. The divorce decree was issued prior to the creation of the lien. The clause in the contract that the buyer will cause the business to pay the taxpayer’s monthly maintenance obligations constitutes a contractual right to payment subject to the attachment of a federal tax lien, the Chief Counsel’s Office said. That the payments are addressed to the taxpayer …

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