- 12 - 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 orPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011