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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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Last modified: May 25, 2011