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Petitioner’s Bankruptcy Proceedings
On January 28, 1997, petitioner filed a chapter 13
bankruptcy petition. The Bankruptcy Court dismissed her case on
March 11, 1999, pursuant to petitioner’s request for a conversion
of her petition. On July 27, 1999, petitioner filed a chapter 7
bankruptcy petition. Schedule E of petitioner’s chapter 7
petition listed income tax liabilities for the taxable years 1991
through 1996, totaling $15,876, as unsecured priority claims. On
November 1, 1999, the Bankruptcy Court granted petitioner a
discharge under 11 U.S.C. sec. 727 (2000).
Petitioner’s Hearing and the Notice of Determination
At the section 6320/6330 hearing on November 29, 2001,
petitioner asserted that the chapter 7 bankruptcy discharge
absolved her of the 1995 and 1996 income tax liabilities.
Petitioner did not present evidence of the alleged “financial
hardship” or of the “discrepancies” in the liability amounts.
Petitioner did not raise any spousal defenses, collection
alternatives, or other challenges to the collection action.
After reviewing petitioner’s 1995 and 1996 account
transcripts and documentation of her bankruptcy proceedings, the
Appeals officer determined that the chapter 7 bankruptcy
discharge had no effect on her 1995 and 1996 income tax
liabilities. The Appeals officer gave petitioner Forms 656,
Offer in Compromise, and 433-A, Collection Information Statement
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Last modified: May 25, 2011