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afford him/her the opportunity to make payment. All
pertinent facts must be carefully considered as the
filing of the notice of lien may adversely affect the
taxpayer's ability to pay and thereby hamper or retard
the collection process. [1 Administration, Internal
Revenue Manual (CCH), sec. 1.2.1.5.13, at 3002-3003.]
Policy statements in the Internal Revenue Manual do not
confer enforceable rights on taxpayers. Vulcan Oil Tech.
Partners v. Commissioner, 110 T.C. 153, 161 (1998), affd. without
published opinions sub nom. Tucek v. Commissioner, 198 F.3d 259
(10th Cir. 1999), Drake Oil Tech. Partners v. Commissioner, 211
F.3d 1277 (10th Cir. 2000). In any event, it is apparent to us
that the IRS met the requirements of the policy statement before
filing the notice of lien. Early in 2000, Rosado contacted
petitioner’s representative, Stone, and discussed with her
payment of amounts owing. His letter of April 19, 2000, enclosed
transcripts of petitioner’s income tax accounts for 1993, 1995,
and 1997. It suggested that petitioner begin making payments of
$5,000 monthly to reduce the amount of tax owing and resulting
interest charges. The letter requested information from
petitioner and explained:
I am required to advise you that failure to provide the
above information by the May 15, 2000 [sic] may result
in enforcement action such as, issuance of Final
Notice, Issuance of Notice of Levy, serving summons,
filing Notice of Federal Tax Lien. * * *
This letter, a copy of which Stone forwarded to petitioner,
adequately provided petitioner with the opportunity to make
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