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with a net realizable equity totaling $170,000. Including other
assets, petitioners’ net realizable equity was reflected by the
IRS as $239,567. The IRS determined that petitioners could pay
their tax liabilities in full.
B. Notice of Federal Tax Lien
A notice of Federal tax lien was filed on October 21, 2003.
On October 24, 2003, respondent issued to petitioners a Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320. Petitioners timely requested a hearing on Form 12153,
Request for Collection Due Process Hearing (Form 12153).
Petitioners explained in the Form 12153 that “Prior to submitting
an offer in compromise, we were making scheduled payments for
several years. If there are no other options we would like to
continue making payments without the lien being placed on the
house.”
Petitioners had a hearing with the IRS Office of Appeals.
After some correspondence between petitioners and the Office of
Appeals, the notice of determination was issued on August 6,
2004. The Appeals officer indicated:
Appeals considered the $5,000 rejected offer to
compromise approximately $27,000 of liabilities. While
your net spendable income was about $1,700 per month it
was the equity in your personal residence that kept the
offer from being accepted.
* * * * * * *
It is not clearly known what your position is although
based upon conversations it appeared they * * *
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