Missing Installment Deal Documents Stymie Government’s Tax Lien

The US government can’t foreclose on a tax lien on a taxpayer’s home because of outstanding questions and the lack of key documentation related to an installment agreement he said was wrongly terminated, a federal judge in New Jersey held.

Judge Julien X. Neals of the US District Court for the District of New Jersey denied the government’s motion for summary judgment Thursday, finding unresolved factual disputes over whether the IRS properly ended Sabatino Paparatto’s agreement to repay $996,377 in trust fund recovery penalties—along with statutory additions, interest, and costs—in installments.

The penalties related to failure to pay over employment ...