This exhibit shows another case scenario example. Type of business: Widget Maker Type of Entity: Corporation Amount of Liability: $200,000 Number of Quarters Delinquent: 4 Years Remaining on Statute: 8 Status/Priority of NFTL: Filed; junior to first lienholder Is Business Current on Deposits? Not in Compliance Number of Employees: 25 Ability to Pay: Unknown, TP has not complied with requests to complete CIS Will Payment Amount Full Pay Within Statute? N/A Status of Trust Fund: Investigation still being completed, CIS needed for collectability determination Levy Sources: Bank Account Accounts Receivable Assets: 10 Trucks Office Furniture, Computers Fair Market Value: $50,000 each $4,000 Encumbrances: $250,000 $0 Additional Facts of Case: Taxpayer had liabilities for a prior corporation that were satisfied through enforced collection. The vehicles were all purchased at the same time and the encumbrance was established when the vehicles were purchased. Levies on bank account and receivables have resulted in minimal funds and have not led to case resolution. Estimated expenses of sale for towing, storage, advertising, etc. are $3,000. Recommended Course of Action: The revenue officer should complete an equity analysis and using 60 % of FMV, the RFSV of the vehicles is $50,000. With estimated expenses of $3,000, the expected net sale proceeds would be $47,000. The taxpayer is a "won't pay" taxpayer because the corporation is not in compliance with Federal Tax Deposits and will not provide financial information. The revenue officer then conducts a risk analysis — there are no reasonable alternative collection methods. The taxpayer does not qualify for an installment agreement or offer in compromise. Other methods of enforcement have already been considered. Since the assets have equity and the risk analysis provides no reasonable alternatives, the seizure should be recommended after all appropriate pre-seizure actions have been completed.