Release of Lien or Discharge of Property

ID: CCA_2010121214444350 Number: 201103045
Release Date: 1/21/2011
Office: ---
UILC: 6325.00-00
From: ---
Sent: Sunday, December 12, 2010 2:44:46 PM
To: ---
Cc: ---
Subject: RE: opinion
It's not really the same situation although the result is the same - i.e., they should not include the payment in computing the Service's interest in the property. The October IG [interim guidance] memo deals with carve-outs to junior lienholders from money that would otherwise go to the senior lienholders. The relocation assistance is not part of the sale proceeds, it's just a payment made directly to the taxpayer and, as such, is not part of the taxpayer's interest in the real property to be discharged from the lien. A new IG memo on this will be coming out soon.