David Jackson and Betty S. Jackson - Page 6

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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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