- 7 - 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’sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007