- 3 - to a Hearing under IRC 6320, on October 21, 2005. In response, petitioners submitted a timely Form 12153, Request for a Collection Due Process Hearing, on November 9, 2005. Petitioners’ hearing was held on January 18, 2006. Pursuant to the parties’ discussions, petitioners signed a Form 433-D, Installment Agreement, on February 10, 2006. Petitioners, via a letter dated February 9, 2006, requested that the NFTL be withdrawn because the lien’s filing would adversely affect their credit rating and could cause them financial hardship. Additionally, petitioners expressed their concern that a lien could affect their ability to secure college loans on their son’s behalf. In response, the IRS sent petitioners a Letter 3193, Notice of Determination Concerning Collection Action(s) Under Section 6320 (notice of determination), on March 28, 2006. The Notice of Determination sustained the NFTL and rejected petitioners’ withdrawal request. Thereafter, petitioners timely filed a petition with the Court. The issues for decision are whether the Appeals officer abused his discretion in: (1) Sustaining the NFTL; and (2) determining that the NFTL should not be withdrawn. Discussion Section 6321 imposes a lien in favor of the United States on all property and rights to property of a person liable for any tax, additions to tax, penalties, interest, and costs that mayPage: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: March 27, 2008