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who agreed with respondent’s Appeals officer that petitioner
should submit an offer in compromise. The accountant later
informed the Appeals officer that petitioner was not interested
in pursuing an offer in compromise. Respondent’s Appeals officer
concluded that respondent should proceed with collection because
petitioner failed to raise any legitimate defenses or
alternatives.
On November 10, 1999, respondent issued petitioner Notices
of Determination Concerning Collection Actions under section 6320
and/or 6330, under which he determined to proceed with collection
by levy.
Petitioner timely filed a petition with this Court pursuant
to section 6330(d)(1), appealing respondent’s determinations to
proceed with collection by levy, alleging the “the deficiency (or
liabilities) as determined by the Commissioner are in income
taxes for the years 1990 through 1996”. In the petition,
petitioner claimed as follows:
Taxpayer was mentally ill from 1993 to 1996 and
unable to make rational decisions. The service [sic]
is aware of the illness.
The taxpayer entered the year 1990 with a Net Fair
Market Value of Assets over Liabilities of $22,000,000.
The taxpayer currently has no assets, only
liabilities.
Real estate values have increased since 1990.
The IRS has in examinations of several of the
years, added tax and the taxpayer has never seen or
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