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Summary of Determination
After discussion of the Notice of Federal Tax Lien
filing at conference, verification that all legal and
procedural requirements were met, review of the
compliance case file and information submitted by the
taxpayer, it was determined that the issuance of the
Notice of Federal Tax Lien Filing was appropriate, and
the action is sustained. The Lien was filed at the
time the taxpayer’s offer in compromise was being
rejected. The Taxpayer’s proposed offer in compromise
was not an acceptable collection alternative. The
taxpayer reports her current employment is a short term
situation, and is unable to fund an offer or an
installment agreement. The taxpayer’s account was
previously closed as currently not collectible under
hardship provisions and should revert to that status.
The record does not include a copy of the notice of Federal tax
lien that is referred to in the notice of determination.
On March 1, 2004, petitioner filed a voluntary petition for
relief under chapter 13 of the Bankruptcy Code with the U.S.
Bankruptcy Court for the Northern District of Georgia.
On March 29, 2004, petitioner filed with this Court a
petition for lien or levy action challenging respondent’s notice
of determination.2 At the time the petition was filed,
petitioner’s bankruptcy case had not been closed or dismissed,
nor had the bankruptcy court granted or denied petitioner a
discharge. See 11 U.S.C. sec. 362(c)(2) (2000).
2At the time the petition was filed, petitioner resided in
Austell, Ga. The envelope in which the petition was mailed was
postmarked Mar. 24, 2004.
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Last modified: May 25, 2011