David Jackson and Betty S. Jackson - Page 7

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               the tax debt.  I notified the Internal Revenue Service                 
               that I was in the process of refinancing.  I sent a fax                
               to them and the lender so that they could check with                   
               the lender to see that this process was in place.  * *                 
               *  The Internal Revenue told me that they would work                   
               with me and they realized that filing the tax lien                     
               would be a hindrance to me getting a loan.  They filed                 
               the tax lien anyway.  In addition to the lien causing a                
               rejection for the loan to pay you it also caused a                     
               rejection for a line of credit for me to even out my                   
               cash flow for the immediate period.                                    
               On August 28, 2003, petitioners faxed to the Internal                  
          Revenue Service (IRS) Lien Desk a letter requesting a “payoff for           
          the attached lien that will be good until September 30, 2003.”              
               On September 16, 2003, petitioners faxed to Revenue Officer            
          Gloria Owen (Ms. Owen) in respondent’s Laguna Niguel office a               
          third request for “a demand to pay off my lien”.                            
               On September 23, 2003, Ms. Owen faxed to petitioners                   
          computer printouts dated September 18, 2003, for each year in               
          issue reflecting petitioner David Jackson’s Social Security                 
          number and the balance due including accrued interest and accrued           
          penalties.  The first page had a handwritten notation stating:              
          “total of all years 1995 through 2001 $64,498.17”.                          
               At some point in time, petitioners began working with Carol            
          Nguyen (Ms. Nguyen), a settlement officer in respondent’s Laguna            
          Niguel office, to obtain a payoff demand for their lender.  On              
          October 10, 2003, Ms. Nguyen faxed to petitioners a document                
          signed by R. Bonzer, Lien Advisor, reflecting petitioners’ escrow           
          number, instructions for payment, and their tax liabilities for             






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