- 3 - In late January 2005, the Government levied against the wages of James J. Crisan (petitioner). Petitioner immediately contacted respondent’s Collection Division (Collections) and began discussing payment options to satisfy the tax liabilities for the years at issue. Collections released the levy against petitioner’s wages and informed him that no collection action would be taken if he and his wife continued to work towards a payment arrangement. Collections gave petitioners until February 21, 2005, to submit financial information and arrange an installment agreement. February 21, 2005, was a Federal holiday. It was not until February 23, 2005, that petitioner was able to reach Collections by telephone to discuss the terms of an installment agreement. The installment agreement between petitioners and respondent became effective March 21, 2005. In accordance with the agreement, petitioner made an initial payment of $5,000 on March 30, 2005, and was to make monthly payments of varying amounts until the liability was paid in full. On March 2, 2005, respondent mailed each petitioner a Notice of Federal Tax Lien Filing and Notice of Your Right to a Hearing Under IRC 6320 (notice of Federal tax lien), with respect to the years at issue. The notice of Federal tax lien advised petitioners of an April 7, 2005, deadline to file a request for aPage: Previous 1 2 3 4 5 6 7 8 NextLast modified: November 10, 2007