129 T.C. No. 17
UNITED STATES TAX COURT
MICHAEL V. SEVERO AND GEORGINA C. SEVERO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6346-06L. Filed November 15, 2007.
With the late filing of their 1990 joint Federal
income tax return, petitioners failed to pay most of
the $63,499 taxes reported due. In 1994, petitioners
filed a bankruptcy petition. In 1998, petitioners
received a bankruptcy discharge order.
In 2004, respondent levied against petitioners’
$196 California income tax refund and notified
petitioners of their appeal rights with regard thereto.
Petitioners did not file an appeal.
In 2005, respondent mailed to petitioners a notice
of Federal tax lien filing (NFTL) and a notice of
intent to make a second levy.
Petitioners requested an Appeals Office collection
hearing relating both to respondent’s NFTL and to
respondent’s notice of intent to make a second levy in
which petitioners claimed that the 1998 bankruptcy
discharge order and the expiration of the collection
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