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THE COURT: So your basic position is that your
debt to the Internal Revenue Service was assumed by the
Federal Government?
MR. WATSON: That is correct, through that
resolution. And I believe in good faith that all
matters have been brought to a conclusion by accord and
satisfaction by the presentation to the agency, the
Internal Revenue Service, for them to present the 1040-
ESs [Forms 1040-ES: Estimated Tax Payment Vouchers]
for payment through the Secretary of the Department of
Transportation or the Secretary of the Department of
Treasury and that would close the matter.
THE COURT: Sir, let me see if I understand your
position.
* * * * * * *
your position is that declarations of estimated tax by
a taxpayer received by the IRS * * * should be
presented to the Secretary of Transportation or the
Secretary of Treasury for payment?
MR. WATSON: Yes, sir.
THE COURT: And that would discharge your tax
liability?
MR. WATSON: Yes, sir.
THE COURT: And that’s why you don’t owe anything
to the Government?
MR. WATSON: Yes, sir.
THE COURT: That’s your case; right?
MR. WATSON: Yes, sir.
D. Section 6330(c)(2)(B)
Petitioner can only challenge the underlying tax liability
if he did not receive the notice of deficiency. See sec.
6330(c)(2)(B).
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Last modified: May 25, 2011