The IRS cоnducted аn аudit оf X Cоrporаtion and assessed the tax liability on April 12, 2013. On August 9, 2024, the IRS filed an NFTL in the state of Oklahoma against X Corporation’s factory building. On September 10, 2024, the IRS sent X Corporation written notice of their intent to seize its property in compliance with IRC § 6335. On November 9, 2024, the IRS seizes the factory building, and engages in a sale that complies with all statutory requirements. Where did the IRS go wrong?