- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
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