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Federal tax lien was issued. Consequently, petitioners were not
negotiating an offer at the time the lien was filed.
The Commissioner “may” withdraw a Federal tax lien pursuant
to section 6323(j)(1), but respondent’s failure to do so in this
case is not an abuse of discretion. See Crisan v. Commissioner,
T.C. Memo. 2007-67; Ramirez v. Commissioner, T.C. Memo. 2005-179;
Stein v. Commissioner, T.C. Memo. 2004-124.
For the foregoing reasons, this Court finds respondent did
not abuse his discretion in sustaining the filing of the second
notice of Federal tax lien, and respondent may proceed with
collections.
In reaching these holdings, the Court has considered all
arguments made and, to the extent not mentioned, concludes that
they are moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: November 10, 2007