- 4 - hearing. The notice of Federal tax lien was recorded on March 7, 2005, with the Recorder of Trumbull County in Warren, Ohio. On April 4, 2005, petitioners submitted Form 12153, Request for a Collection Due Process Hearing, in which they claimed the notice of Federal tax lien should not have been filed because of representations made by Collections personnel that no further collection action would take place while they were negotiating an installment agreement. Petitioners also claimed that the notice of Federal tax lien would impair their credit, making it impossible to obtain financing. On July 13, 2005, a hearing was held by telephone between petitioner and Settlement Officer Marlene M. Okajima-Garcia (Ms. Okajima-Garcia), who had earlier mailed petitioners a letter which listed the statutory requirements to obtain a withdrawal of a notice of Federal tax lien pursuant to section 6323(j). During the hearing, petitioner argued that the Federal tax lien was filed prematurely at the time he was negotiating an installment agreement with Collections and, because petitioners entered into an installment agreement, the notice of Federal tax lien should be withdrawn. On July 22, 2005, respondent’s Appeals Office issued petitioners the notice of determination sustaining the filing of the notice of Federal tax lien and finding that none of the statutory requirements for withdrawal pursuant to section 6323(j)Page: Previous 1 2 3 4 5 6 7 8 NextLast modified: November 10, 2007