"As of December 31, 2012, the Company had an obligation for $17.6 million in delinquent payroll taxes plus $1.4 million in accrued penalties. These amounts are due to the US Treasury and represent collection of employment taxes from its PEO employees. The U.S. Treasury and Internal Revenue Services (IRS) will have a priority interest in all assets of the Company."
They can't issue dividendS or stock or do a lot of things because the IRS has a priority interest in ALL ASSETS OF THE COMPANY.
All authorized but unissued shares of the company are ASSETS.
I'm not suggesting you take my word for it. I'm just an internet poster --> go ask the IRS exactly what "priority interest in all assets of the Company" means