- 3 - On October 28, 2005, respondent filed a Federal tax lien in Washington County, Minnesota, relating to petitioners’ 1999 outstanding Federal income taxes. On or about November 2, 2005, petitioners timely requested an Appeals Office hearing, seeking to avoid or at least to postpone respondent’s proposed levy. In their Appeals Office hearing, petitioners requested that respondent designate their outstanding 1999 Federal income taxes as currently not collectible. Petitioners also represented that because of the balloon payment due on their contract for deed in June of 2007 they intended to sell or refinance their residence and that funds therefrom would be used by petitioners to pay their outstanding 1999 Federal income taxes. Petitioners also represented that they had several business deals that at some point might provide funds to pay their 1999 Federal income taxes. In the Appeals Office hearing petitioners did not challenge their underlying 1999 Federal income tax liability. Per respondent’s request, petitioners filed Form 433-A, indicating that petitioners’ monthly living expenses exceeded their monthly earned income and showing their residence as their only significant asset. On or about April 26, 2006, respondent’s Appeals officer advised petitioners’ representative that the proposed levy actionPage: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007