- 8 - failure to do so in this case is not an abuse of discretion. Ramirez v. Commissioner, supra; Stein v. Commissioner, supra. Petitioners did not produce any evidence to support their contention that the filing of the notice of Federal tax lien would impair their ability to pay their outstanding liabilities. On the basis of the facts presented, this Court holds that respondent did not abuse his discretion in sustaining the filing of the notice of Federal tax lien. In reaching these holdings, the Court has considered all arguments made and, to the extent not mentioned, concludes that they are moot, irrelevant, or without merit. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8Last modified: November 10, 2007