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their loan officer at World Savings who was handling the
refinancing of their home.
B. Filing of the Notice of Federal Tax Lien
On June 19, 2003, respondent filed a notice of Federal tax
lien against petitioners for income taxes (including interest and
additions to tax) for the years in issue. On June 24, 2003,
respondent sent each petitioner a Notice of Federal Tax Lien
Filing and Your Right to a Hearing Under IRC 6320 for the years
in issue.
On July 3, 2003, petitioners sent a letter to respondent’s
Laguna Niguel office requesting that their case be forwarded to
the Office of Appeals. In their request, petitioners stated that
“Mrs. Partridge stated that she would work with me and not file a
lien if I would refinance” and that “such a filing would impede
my ability to pay taxes”.
On or about July 14, 2003, petitioners submitted to World
Savings a loan application for approximately $60,000 at an
interest rate of 4 percent. On July 16, 2003, World Savings
denied petitioners’ July 14, 2003 loan application because of
petitioners’ “poor credit performance with us [World Savings]”.
On July 27, 2003, petitioners submitted to respondent a Form
12153, Request for a Collection Due Process Hearing. Petitioners
attached to the Form 12153 a statement stating, in part:
I disagree with the filing of the federal tax lien
because it has prohibited me from refinancing to pay
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