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wit: The release of the Notice of Federal Tax Lien because it
was causing petitioner a significant hardship. The
representative proposed that if respondent released the Notice of
Federal Tax Lien, respondent could record a new notice if
petitioner defaulted with respect to the payments under the
installment agreement.
On December 17, 2002, the Appeals officer engaged in a
telephonic conference with petitioner and his representative.
Petitioner’s representative agreed that the administrative
requisites had been followed or met by respondent. Petitioner’s
representative also explained that petitioner was attempting to
refinance property and that respondent should release the Notice
of Federal Tax Lien because an installment payment agreement had
been entered into with petitioner. The Appeals Office advised
that a notice of lien is not released until the liability is
satisfied or becomes uncollectible as a matter of law.
Following the telephone conference with petitioner and his
representative, the Appeals officer, on February 20, 2003, issued
a notice of determination. In the accompanying writeup, the
Appeals officer explained that the Notice of Federal Tax Lien
would not be released and that the notice was not released as a
matter of right if a taxpayer entered into an installment
agreement. Petitioner resided in Jupiter, Florida, when he
timely filed his petition with this Court.
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Last modified: May 25, 2011