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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 the
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