On April 6, 2020, the American Bar Association Section of Taxation submitted additional comments to the IRS (available here) requesting further relief for taxpayers affected by the COVID-19 emergency. The requested relief includes, but is not limited to: a complete suspension of all enforced collection activity by the IRS and a mechanism for taxpayers to have notices of federal tax lien subordinated to allow taxpayers to obtain new, or refinance existing, debt.
We will continue to keep you updated of any developments with respect to further relief granted by the IRS. Questions about these comments, or any IRS matter, can be directed to Larry Sannicandro at (973) 639-2081 or LSannicandro@mccarter.com.