Mr. Nelson observed: "I thought they'd be crazy not to take it. The very fact they see a way to make a lot of money real quick made them go for it. They're not interested in sitting around waiting 10 or 20 years for the money to trickle in."

Last November, the Government seized Mr. Nelson's homesteads in three states, padlocked his recording studio, and arranged to auction off his gold records and the family piano. By then, the Government had agreed to take about $15 million less than it originally wanted, but the 58-year-old singer and songwriter was having trouble coming up with cash. Running out of patience, the Government confiscated almost everything but his talent and beat-up Martin guitar.

The ailing real estate market in Texas meant that the sales of Mr. Nelson's property reduced his debt by less than $2 million. That left Mr. Nelson with a seemingly insurmountable $15 million obligation. A Trove of Old Songs

But Mr. Nelson persuaded the I.R.S.'s district office in Austin, Tex., which is handling his case, to make a major concession in May. It granted him access to 35 years' worth of seized tapes that he had squirreled away in his Spicewood, Tex., recording studio. Out of that trove, Mr. Nelson created "Who'll Buy My Memories? (The I.R.S. Tapes)."

"It's no overproduced album with millions of dollars of studio costs," Mr. Nelson said. "But I think it's the best stuff I got. I've always wanted to put out an album with me and my guitar doing my original songs. And my fans like it because it sounds like it's just me in my living room singing."

Mr. Nelson, considered a patriarch and icon of country music, made his reputation as a maverick and songwriter. In the early 1960's, his "Night Life" became Ray Price's theme song, and "Crazy" was a hit for Patsy Cline (and, years later, for Linda Ronstadt). Mr. Nelson's "Funny How Time Slips Away" has been widely recorded.

While he also recorded as a singer, his grainy voice did not fit the increasingly slick style of Nashville productions, and in the 1970's, Mr. Nelson moved back to Texas and began recording with more homespun backup. Albums That Tell Stories