Oliver W. and Harriet S. Williams - Page 7




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          Federal tax lien was prematurely filed because petitioners were             
          negotiating an offer-in-compromise, and the second notice of                
          Federal tax lien did not reflect that the 2004 overpayment credit           
          of $4,664 was applied to reduce the balance owing.                          
               In response, Mr. Knauss informed petitioner that he could              
          not reinstate a returned offer-in-compromise, an offer-in-                  
          compromise does not prohibit the filing of a notice of Federal              
          tax lien, and the amount shown on a notice of Federal tax lien is           
          not reduced when a taxpayer makes a subsequent payment.                     
               At the hearing, petitioner proposed an offer-in-compromise             
          or an installment agreement as a collection alternative.  Mr.               
          Knauss and petitioner agreed that petitioners would provide a               
          completed Form 433-A to Mr. Knauss by November 28, 2005, so that            
          Mr. Knauss could determine which collection alternative would               
          suit petitioners’ financial situation.                                      
               On November 23, 2005, petitioners faxed a letter to Mr.                
          Knauss requesting an extension until December 15, 2005, to                  
          provide the completed Form 433-A.  Petitioners failed to provide            
          the Form 433-A by December 15, 2005, or anytime thereafter.                 
               On January 12, 2006, respondent’s Appeals Office issued                
          petitioners a notice of determination sustaining the filing of              
          the second notice of Federal tax lien and finding:                          
               The taxpayers have been given multiple opportunities to                
               resolve these liabilities via less intrusive means but                 
               have failed to do so in a timely manner.  The filing of                
               the NFTL is the only means of securing the government’s                






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