David and Monika Zisskind - Page 6

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          respondent determined petitioners were liable for an addition to            
          tax under section 6651(a)(2) because they did not establish that            
          their failure to pay the tax shown on their return was due to               
          reasonable cause.3  Respondent also determined petitioners were             
          not entitled to an abatement of interest.  Because petitioners              
          “provided no concrete information as to how the collection would            
          be facilitated” if the notice of Federal tax lien were withdrawn,           
          respondent determined the Federal tax lien should not be                    
          withdrawn.  Respondent verified that all statutory and                      
          administrative requirements were met and concluded that the                 
          filing of the notice of Federal tax lien was appropriate.                   
               In response to the notice of determination, petitioners                
          filed a petition with this Court on August 8, 2005.                         
               Section 6321 imposes a lien in favor of the United States on           
          all property and rights to property of a taxpayer liable for                
          taxes when a demand for payment of the taxes has been made and              
          the taxpayer fails to pay those taxes.  Section 6320(a) provides            
          that the Secretary shall furnish the taxpayer with written notice           
          of a Federal tax lien within 5 business days after the notice of            
          lien is filed.  Section 6320 further provides that the taxpayer             

               3  Because respondent found petitioners were not liable for            
          the addition to tax under sec. 6651(a)(1), respondent increased             
          the amount of the addition to tax under sec. 6651(a)(2) by $4,725           
          to $6,620.                                                                  

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