Randal W. Howard - Page 14

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          document need be provided to a taxpayer at an administrative                
          hearing conducted under section 6330, and that a Form 4340 (such            
          as those included in this record) and other transcripts of                  
          account satisfy the verification requirements of section                    
          6330(c)(1).  See  Roberts v. Commissioner, 118 T.C. 365, 371 n.10           
          (2002), affd. 329 F.3d 1224 (11th Cir. 2003); Nestor v.                     
          Commissioner, 118 T.C. 162, 166 (2002); Lunsford v. Commissioner,           
          117 T.C. 183 (2001).                                                        
               Petitioner also asserted that his tax liabilities for 1983             
          and 1993 to 1995 were discharged by the bankruptcy court.  The              
          Court has jurisdiction in a collection review proceeding to                 
          determine whether the unpaid tax liabilities in dispute were                
          discharged in a bankruptcy proceeding.  Washington v.                       
          Commissioner, 120 T.C. 114, 120-121 (2003).                                 
               The record reflects that, on December 6, 1996, petitioner              
          voluntarily filed a bankruptcy petition under chapter 7 of the              
          Bankruptcy Code.  Although the bankruptcy court issued an order             
          of discharge in that case, petitioner’s unpaid tax liabilities              
          for 1983 and 1993 to 1995 were not discharged because petitioner            
          failed to file tax returns for those years.  See 11 U.S.C. sec.             
          523(a)(1)(B)(i) (2000); Swanson v. Commissioner, 121 T.C. 111,              
          124-125 (2003).                                                             
               Petitioner's assertion that respondent's motion should be              
          denied on the ground respondent failed to demonstrate that                  






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