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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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