James J. and Veronica L. Crisan - Page 6

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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                     
                         (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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