Redemption by United States

ID:
Office:
UILC:
CCA_2009091114430603
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7425.05-00
Number: 200945052
Release Date: 11/6/2009
From: ---
Sent: Friday, September 11, 2009 2:43:22 PM
To: ---
Cc: ---
Subject: RE: Sale of redemption right
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Nothing in the Internal Revenue Code authorizes the Service to sell a right of redemption. However § 7425(d)(1) specifically limits redemption to the Secretary. In addition, for a fee, the Service may release a right of redemption. The Service may only release a right of redemption to a party with a proper interest in the property sold. 28 U.S.C. § 2410(e); Treas. Reg. § 301.7425-4(c)(4). The Service cannot release the right to redeem property to a third party.
Because the Code does not authorize the sale of a redemption right and the release of a right of redemption is limited to parties with a proper interest in the subject property, it follows that the Service cannot sell the right to redeem property to a third party.
Please let me know if you have any questions or concerns.
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