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claim totaling $34,150.32 for 1983 and 1984. On April 14, 1994,
Mr. Greenfield’s action under chapter 11 of the Bankruptcy Code
was converted to a bankruptcy liquidation under chapter 7.
On August 15, 1994, respondent filed a third proof of claim
in Mr. Greenfield’s bankruptcy proceeding (third proof of claim).
Respondent’s third proof of claim asserted an unsecured priority
claim totaling $216,386.49 and an unsecured general claim
totaling $19,601.28 for 1983, 1984, and 1991.
On November 18, 1997, the U.S. Bankruptcy Court for the
Southern District of Florida issued a “Discharge of Debtor(s)”.
On July 19, 2000, the bankruptcy trustee paid respondent
$29,683.67 in satisfaction of respondent’s unsecured priority
claim of $216,386.49. On July 21, 2000, respondent advised the
Greenfields by correspondence that their only open Federal tax
lien was filed in July 1995.
On April 25, 2006, the Estate of Marvin E. Greenfield filed
a Form 4810, Request for Prompt Assessment Under Internal Revenue
Code Section 6501(d), for the income tax years 1980 to 1986
inclusive. In response to that request, on October 11, 2006, in
correspondence directed to the Greenfields, respondent mistakenly
stated that the period of limitations for 1982 had already
expired.
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Last modified: March 27, 2008