Stuart Hult - Page 7




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               In a Form 9423, Collection Appeal Request, dated September             
          23, 2003, petitioner appealed Mr. Barry’s decision to file a                
          Notice of Federal Tax Lien.  In that document petitioner argued             
          that a Notice of Federal Tax Lien should not be filed because,              
          among other reasons:  (1) The 2003 offer was still pending; (2)             
          filing the notice would add to the health problems he was                   
          suffering as a survivor of the terrorist attack on the World                
          Trade Center; (3) he was cooperating fully with respondent in               
          attempting to resolve his tax problems; (4) filing the notice               
          would adversely affect his ability to obtain credit; and (5)                
          filing the notice could adversely affect his ability to secure              
          future employment.                                                          
               Petitioner’s appeal of Mr. Barry’s decision to file a Notice           
          of Tax Lien was handled by Appeals Officer Deborah L. Ross.                 
          After conferring with petitioner’s representative, Ms. Ross, in a           
          comprehensive memorandum dated October 20, 2003, that addresses             
          each of the arguments advanced by petitioner, “sustained” Mr.               
          Barry’s decision to file a Notice of Federal Tax Lien with                  
          respect to petitioner’s outstanding tax liabilities.  The letter            
          advising petitioner of Ms. Ross’s decision, and the reasons for             
          that decision, also notified petitioner that if he were to                  
          “successfully negotiate an acceptable offer-in-compromise, the              
          lien would be released upon payment of the amount offered”.                 








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