David and Ludmila Klet - Page 4

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               On September 30, 1996, petitioners filed a bankruptcy                  
          petition under Chapter 13 of the United States Bankruptcy Code in           
          California.  On October 15, 1996, the Internal Revenue Service              
          filed a proof of claim in petitioners’ bankruptcy proceeding                
          which included $45,814.97 in income tax liabilities plus interest           
          for the four years.  On November 1, 1996, petitioners’ bankruptcy           
          proceeding was converted from a Chapter 13 to a Chapter 7                   
          bankruptcy proceeding.  On March 14, 1997, the bankruptcy court             
          entered an order of discharge in the petitioners’ bankruptcy                
          case.                                                                       
               On February 11, 2003, respondent filed a Notice of Federal             
          Tax Lien with the Los Angeles County Recorder’s Office in                   
          connection with petitioners’ unpaid income tax liabilities for              
          the four years.  On February 14, 2003, respondent issued to                 
          petitioners a Notice of Federal Tax Lien Filing and Your Right to           
          a Hearing Under IRC 6320 (the notice), which advised petitioners            
          that a notice of Federal tax lien has been filed with respect to            
          their unpaid income tax liabilities for the four years, and that            
          petitioners were entitled to a hearing.                                     
               On March 25, 2003, petitioners timely filed Form 12153,                
          Request for Collection Due Process Hearing.  In their request,              
          petitioners claimed that the tax liabilities for the four years             
          were discharged in the bankruptcy proceeding.                               
               On December 9, 2003, a face-to-face conference was held                






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