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sec. 301.6323(j)-1(c), Proced. & Admin. Regs.; see also Crisan v.
Commissioner, T.C. Memo. 2007-67.
Finally, petitioners did not submit any evidence to
demonstrate that the withdrawal would facilitate collection or
would be in the best interests of the taxpayer and the United
States. Petitioners testified that the NFTL may cause their
interest rates to increase on their other debts so withdrawal of
the NFTL would help them and in turn the United States. But
petitioners’ assertion that the withdrawal of the lien would
facilitate collection and would be in the United States’ best
interest is only conjectural. There has been no showing that the
filing of the lien has in fact caused the interest rates on their
other obligations to increase sufficiently to impair collection.
The Court concludes that respondent’s Appeals officer did
not abuse his discretion in refusing to withdraw the NFTL.
Accordingly, respondent’s determination is sustained.
To reflect the foregoing,
An appropriate decision will
be entered.
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Last modified: March 27, 2008