However, Plaintiff offers no legal or factual basis to suggest that Revenue Officer Palmer or any other IRS employee mishandled the Ryans' lien subordination application. Even though Palmer, as a Revenue Officer, was not authorized to formally reject the Ryans' lien subordination application, see Kugler v. United States, 2000 WL 1274230, at *3 (W.D. Pa. July 10, 2000) (stating that 26 C.F.R. § 301.6325-1(d) "does not permit a revenue officer to deny a written application for a certificate of subordination"), Plaintiff acknowledges that the Ryans' application was never formally rejected by anyone. See Pl. Opp. at 17 (asserting that the application "was never processed or acted on" and was instead "de facto reject[ed]").