Congress should adopt the following provision related to seizure action:

    The Secretary shall be prohibited from making a levy where it is
    apparent at any time prior to seizure that the value of the U.S.
    interest in the property is insufficient to meet the expenses of
    seizure and sale.

Reasons for Change:

This provision would protect taxpayers from harassment seizures or seizures made merely to "teach the taxpayer a lesson." The Internal Revenue Manual prohibits this kind of activity, and codifying the prohibition would help to guarantee compliance.