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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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Last modified: November 10, 2007