“However if lien recorded on real estate, the lien would last beyond 10 years depending on state law.”
Not sure about the 10 year lien rule. Doesn’t sound right. I would fight it after doing case research. The 10 year rule is by statute. They can’t enforce a lien on a debt not owed.
Had one client where the IRS accidentally left the lien expire.. usually 5 year renewals required. Client sold the real property and the IRS was pissed but could do nothing.
There are exceptions to the 10 year period for bankruptcies, installment agreements, statute extensions, offers in compromise..... I never had one in 40 years.
Hate to say it, but the collection agents are so overworked that they don’t have time to chase after the old items. Field audit is even worse. My friends who work at the IRS can’t wait to retire and most already have. (I used to teach tax law programs with the IRS in several regions)
CID is really getting bigger and much more aggressive. They carry guns and work undercover doing sting operations, often in drug rings and organized crime task forces. We invite them to our annual tax updates to hear the interesting stories.
I assume IRS would obtain judgement.