The Internal Revenue Service may have difficulty collecting much of the $4.5 million in back taxes that it claims are owed by South Korean businessman Tongsun Park, even though the IRS filed tax liens against Park throughout the Washington area and as far away as Los Angeles last week.

According to a Washington Post analysis of Park's financial holdings, based on information from records and several of his associates, Park has transferred many of his assets out of this country during the past year.

Park is the central figure in a Justice Department investigation of South Korean government attempts to "create a favorable legislative climate" with money. Park allegedly dispensed between $500,000 and $1 million annually in cash, gifts and campaign contributions to U.S. congressmen and other officials during the 1970s, according to information, including intelligence reports, recevied by federal investigators.

The attempt by the IRS to prevent Park from liquidating more of his assets in the U.S. by attaching his bank accounts and property may also be frustrated by a multitude of mortgages and loans from Washington banks and financial institutions, which are secured by his remaining assets here.

One of Park's few nearly unencumbered assets, Suters Tavern, Inc., the corporation that operates the fashionable private George Town Club has not been contacted by the IRS and apparently no lien has been filed against the corporation.

Park associates insist that Park is well prepared to prove that he was not subject to U.S. taxes because since he was a nonresident alien throughout the tax years in question - 1972 through 1975 - and his income came only from foreign corporations.

Four years ago, they noted, the IRS also submitted a substantial bill to Park for back taxes, but Park's lawyers prevailed and the IRS ruled that Park was not liable for any U.S. tax. The IRS did not attach his assets at that time.

Park's U.S. corporation file tax returns, his associates said, but pay no taxes since they show no profits.

While the IRS may no collect any back taxes from Park, they are likely to discover a fascinating web of foreign and U.S. businesses that Park has operated over the past decade, sources close to Park said.

Among the mysterious business deals the IRS will soon be attempting to untangle is the transfer of $275,000 from one of Park's Bermuda bank accounts through a U.S. bank account to former U.S. Rep. Cornelius Gallagher in the fall of 1975.

At the time, Park told his employees that he intended to invest in a pork slaughter house in New Jersey. After they advised against the purchase, however, Park decided not to invest according to the sources. Yet several months later, Park transfered to Gallagher the money that originally had been set aside as the down payment.

Park's business associates do not know of any interest he now holds in the slaughter house.

The Justice Department has been reviewing Park's financial records as part of its investigation of Korean influence peddling and has received grand jury testimony about the Gallagher payment and other unusual transactions.

The federal investigators have been unable to decipher much of Park's complicated finances, however. His funds were often commingled in accounts kept both here and abroad without identification of their original source and then transferred in huge cash payments to other accounts and commingled with other funds.

Park's complicated business affairs derive largely from his desire to conceal his true situation and his history of shaky finances, according to his former business associates.

During the 1960s, Park cultivated the image of the successful enterpreneur. In fact, Park was living one day at a time, a step ahead of his creditors, borrowing hundreds of thousands of dollars against his property from dozens of sources, pyramiding his properties with new loans, often going to unscrupulous lenders who charged tens of thousands of dollars off the top.

It was during this time that Park founded the company that operates the George Town club, a private social club used by members for entertaining, and bought several large homes here.

During the 1970s, however, Park's resources apparently began to match his princely life style. His commissions on rice purchased by the Korean government from American growers, his fees from providing ship crews to international oil companies, and his $3 million commission from the Burmah oil company for assistance in negotiating of a settlement of a dispute with Japan Line, Ltd., began generating huge amounts of cash.

In order to avoid U.S. income taxes, Park had these fees paid to foreign corporations. The Burmah Oil Co., for example, has acknowledged recently paying the $3 million fee to Fontas, Ltd., a Park-owned corporation in Bermuda.

In order to generate cash for his use here, Park often transferred huge quantiuties of cash here from his foreign accounts. In one particular month, he wrote nearly $1 million in checks to "cash," informed sources said.

Much of this cash was brought into the U.S. by courier and delivered to his house by armored car.

Park also used millions in these foreign funds to lend capital to his U.S. corporations, Pacific Development Corporation and Suters Tavern Inc. Pacific Development is a personal investment company for Park that does little besides manage his investments here and provides logistical support in the U.S. for his business deals aborad. Suters Tavern Inc. operates the George Town Club.

According to Park associates, both corporations are designed by Park to absorb the maximum amount of his expense in the U.S. and show little if any taxable profit.

Over the past decade, Park, who is now living in London and reportedly commutes to Abu Dhabi and the Dominican Republic, has spent only about four months of each year in this country according to Norman Larsen, the manager of the George Town Club. Larsen noted that Park travels regularly on his international business deals.

When Park started out in the mid-1960, he also returned regularly to Korea. According to his financial consultant during that period, Jack Kelly, Park regularly went there for two reasons.

"To avoid paying income taxes here, he had to live out of the United States 184 days of the year," Kelly says. "I sent him home to Korea. Also, with him out of the country, I could stall all the banks who were threatening to foreclose and the creditors who were suing."

According to Kelly, Park was $1.1 million in debt when he went home to Korea in 1969. At the time Park had even hocked his revered mother's antique jade hairpins as collateral for his rapidly expanding commercial and personal debts.

Nevertheless, over the past 11 years Park has managed to lend nearly $1 million to Suter's Tavern, Inc., the corporation that operates the Georgetown Club.Park recently converted the remaining "substantial" balance of the loan into the stock, according to larsen. This would seem to comprise Park's major assets in this country.

Park's other remaining assets have include an office building at 1604 K St. NW, which Park has put up for sale for $750,000; a mansion at 2211 30th St. N.W. for which Park is asking $750,000 and 2850 Woodland Dr. NW for which he is asking considerably more than the half million dollars he paid for it.According to real estate sources and a business associate of Park, all the properties are now owned by Park's Pacific Development Corporation.

Park's interest in the 3040 M Street Corp., which operates the Pisces Club, a gathering for the self-preceived socially prominent, has been attached by the IRS. Pisces was originally opened with loans totalling $290,000 from Pacific Development, and Park guaranteed a $100,000 loan for it from the National Bank of Washington. Park also owns a substantial amount of 3040 M Street Corp. stock, according to a Park associate.