No, this is not an essay on tariffs and trade. Rather, ex-Ch J L. Paige (“Iron Fist”) Marvel Judge-‘splains the broad discretion for releasing (or not) NFTLs.

Bobby G. Glaser and Cathleen A. Glaser, T. C. Memo. 2025-66, filed 6/23/25, want IRS to lift the NFTL imposed when they renegotiated their existing IA to pick up two (count ’em, two) new years.

The Letter 2603C that granted their requested revision stated “Although you made arrangements with us to pay your tax monthly, if you don’t pay the entire amount you owe by May 08, 2023, we may file a Notice of Federal Tax Lien to protect the government’s interest.” T. C. Memo. 2025-66, at p. 3. The Glasers didn’t pay, IRS filed the lien, and the Glasers petitioned Appeals’ sustentation thereof.

But the Glasers don’t show that IRS didn’t follow procedures, and the Letter 2603C properly reserved IRS’ right to file the NFTL. Nor did the Glasers show that the NFTL impeded their ability to pay pursuant to their revised IA.

That their pre-amendment IA didn’t result in a NFTL is nothing to the point. To get it lifted, proof is needed that the NFTL does more harm than good.

NFTLs protect the government’s position until payoff.