James J. and Veronica L. Crisan - Page 3

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               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 a           

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