Simon L. and Patricia M. Richard - Page 20

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          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          at issue should not be withdrawn.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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