James J. and Veronica L. Crisan - Page 8

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          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.             

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