- 6 - v. Commissioner, supra at 293. The notice of Federal tax lien is filed with the appropriate State office or other government office in order to validate the lien against any purchaser, holder of a security interest, mechanic’s lienor, or judgment lien creditor. See sec. 6323(a); Lindsay v. Commissioner, T.C. Memo. 2001-285, affd. 56 Fed. Appx. 800 (9th Cir. 2003). Section 6323(j)(1) provides in pertinent part: SEC. 6323(j). Withdrawal of Notice in Certain Circumstances.-- (1) In general.--The Secretary may withdraw a notice of a lien filed under this section * * * if the Secretary determines that-- (A) the filing of such notice was premature or otherwise not in accordance with administrative procedures of the Secretary, (B) the taxpayer has entered into an agreement under section 6159 to satisfy the tax liability for which the lien was imposed by means of installment payments, unless such agreement provides otherwise, (C) the withdrawal of such notice will facilitate the collection of the tax liability, or (D) with the consent of the taxpayer or the National Taxpayer Advocate, the withdrawal of such notice would be in the best interests of the taxpayer (as determined by the National Taxpayer Advocate) and the United States. Petitioners contend the Appeals officer, Ms. Okajima-Garcia, abused her discretion by failing to withdraw the notice of Federal tax lien (1) under section 6323(j)(1)(A) because thePage: Previous 1 2 3 4 5 6 7 8 NextLast modified: November 10, 2007