- 8 - As noted above, on or about October 21, 2003, a Notice of Federal Tax Lien was filed with respect to petitioner’s outstanding tax liabilities (the NFTL). By letter dated October 27, 2003, petitioner was advised of the event and notified of his right to request an administrative hearing to dispute it, which he did in a request dated November 27, 2003. A short time earlier, by letter dated November 19, 2003, petitioner was advised that the 2003 offer had been rejected because: (1) It was “less than * * * [petitioner’s] reasonable collection potential”; and (2) petitioner had “failed to provide the requested information and documentation” about his wife’s income and expenses. That letter also advised petitioner that he could appeal the rejection of the 2003 offer, which he did by letter dated December 18, 2003. Petitioner’s request for an administrative hearing with respect to the NFTL and his appeal of the rejection of the 2003 offer were assigned to Settlement Officer Michael Blais (Mr. Blais). For reasons discussed in a memorandum dated December 15, 2004, Mr. Blais upheld the rejection of the 2003 offer. During the administrative hearing conducted in connection with the NFTL, petitioner offered an installment agreement as an alternative collection action. Under the terms of the proposed installment agreement, petitioner offered to pay $100 per monthPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007