- 5 - 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 payPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011