Morris Tabak - Page 5




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          Federal tax lien because:                                                   
               Lien will put me out of business.  Also working on                     
               obtaining a loan to pay off balance of $25,601.85.                     
               Payments have been made.                                               
               E.  The Appeals Office Hearing                                         
               On July 24, 2001, petitioner attended an administrative                
          hearing conducted by an Appeals officer from respondent’s Appeals           
          Office in Houston, Texas.                                                   
               At the hearing,2 petitioner did not challenge the underlying           
          tax liability for either 1997 or 1998.  Rather, petitioner                  
          expressed concern that the notice of Federal tax lien would                 
          negatively affect both his business and his ability to borrow.              
          In this regard, petitioner indicated that his financial situation           
          was not strong and that he had not been successful in obtaining             
          financing to satisfy his outstanding Federal tax liabilities.               
          The possibility of entering into an installment agreement or                
          filing an offer in compromise was discussed; however, because of            
          petitioner’s continuing failure to pay estimated tax and to be              
          current in his Federal tax obligations, the Appeals officer                 
          indicated that it would not be possible to pursue either of those           
          alternatives.                                                               




               2  Our findings for this paragraph are based on the Appeals            
          officer’s Case Memorandum.  Petitioner has not challenged or                
          otherwise questioned any of the statements of fact appearing in             
          that memorandum.                                                            





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