- 7 - Appeals officer or (2) settle with the Internal Revenue Service (IRS).6 On September 28, 1999, following inaction by petitioner, the Appeals officer issued a notice of determination deciding “not to withdraw the Notice of Federal Tax Lien.”7 In the notice of determination, the Appeals officer explained that petitioner’s “tax was not dischargeable” pursuant to applicable bankruptcy law and that petitioner had “signed a stipulation waiving the restrictions prohibiting assessment and collection of the deficiency and additions to tax (plus statutory interest) for the taxable year 1990”. Petitioner, thereafter, petitioned this Court to review respondent’s determination pursuant to section 6330. In the petition, petitioner contends that (1) he has never received (or had the opportunity for) an Appeals hearing, (2) the Tax Court decision with regard to the tax deficiency and additions to tax should be vacated because of the previous bankruptcy action, and (3) respondent is not entitled to interest for the period during 6 The Appeals officer suggested to petitioner the following alternatives for settlement: 1. Full payment of the liability. 2. Enter into an installment agreement. 3. Submit an offer in compromise, [based on] doubt-as- to collectibility. 7 There are no indications in the record that after speaking with the Appeals officer, petitioner requested an Appeals hearing to be held at the Appeals Office in Sunrise, Florida.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011