- 19 -
and 1997, respectively, are overpayments that are similarly
available as of the date paid. We conclude that the Appeals
officer abused her discretion in failing to take the foregoing
payments and credits into account when determining that the liens
at issue should not be withdrawn. Because the interest
computations attendant to the application of the foregoing
payments and credits cannot be made on this record, we shall
remand this case to respondent's Appeals Office for further
consideration.
To reflect the foregoing,
An appropriate order will be
issued.
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