Quatloos! :: View topic - 861 non-withholding employers file fake liens: "Defendants have provided no evidence demonstrating that the UCC Financing Statement is based on legitimate debt or law, or controverting the facts set forth above. Rather, defendants have provided documents that appear to have been created by defendants, none of which were adjudicated in a court of law. It appears defendants claim that a debt arose as a result of the failure of the employees to respond when defendants mailed documents to them. However, the courts do not recognize the legality of such a 'lien.' United States v. Andra, 923 F.Supp. 157, 159-60 (D. Idaho 1996). Defendants have not provided any evidence of a contractual or other legal relationship with any IRS employee to establish the validity of the UCC Financing Statement filed by defendants. "