A “nominee” is someone who holds property “in name only” for the benefit of another. An “alter ego” is the use of another name for one’s self, and does not involve another individual. The IRS will sometimes assert that property is held by a nominee when someone other than the taxpayer against whom the IRS is seeking to assess or collect has legal title but the taxpayer, in substance, enjoys the benefits of ownership of the property. A tax lien can attach to property that really belongs to a taxpayer even if the taxpayer’s name is not on […]