The appeal
(2) Form. The appeal shall include the following information and documents: (i) Name, current address, and taxpayer identification number of the person appealing the filing of notice of federal tax lien; (ii) A copy of the notice of federal tax lien affecting the property, if available; and (iii) The grounds upon which the filing of notice of federal tax lien is being appealed. (A) If the ground upon which the filing of notice is being appealed is that the tax liability in question was satisfied prior to the filing, proof of full payment as defined in paragraph (e) of this section must be provided. (B) If the ground upon which the filing of notice is being appealed is that the tax liability that gave rise to lien was assessed in violation of the deficiency procedures set forth in section 6213 of the Internal Revenue Code, the appealing party must explain how the assessment was erroneous. (C) If the ground upon which the filing of notice is being appealed is that the tax liability that gave rise to the lien was assessed in violation of title 11 of the United States Code (the Bankruptcy Code), the appealing party must provide the following: