Nancy B. Doyle - Page 9




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          The Bankruptcy Case                                                         
               On May 5, 1995, petitioner and her husband filed a voluntary           
          petition for liquidation under chapter 7 of the U.S. Bankruptcy             
          Code in the U.S. Bankruptcy Court for the Western District of               
          Pennsylvania (the bankruptcy case).  In the bankruptcy case,                
          respondent filed a $379,025.90 proof of claim.  On June 17, 1996,           
          the bankruptcy court granted the Doyles a discharge pursuant to             
          11 U.S.C. sec. 727.                                                         
               In this case, petitioner initially contended that the income           
          taxes at issue were discharged in the bankruptcy case. Petitioner           
          conceded before trial that her joint and several income tax                 
          liabilities for the years 1980 through 1983 were excepted from              
          bankruptcy discharge pursuant to 11 U.S.C. sec. 523(a)(1)(C).               
          Payment of Tax Deficiencies                                                 
               The Doyles have not made any voluntary payments on their               
          assessed tax liabilities.  During 1994 and 1995, respondent                 
          placed a continuing levy on the wages of petitioner’s husband               
          which resulted in the receipt of $34,672.71 and $14,132.45,                 
          respectively.  On June 5, 1995, respondent applied a $6,345                 
          overpayment due the Doyles to their 1980 tax liability.  In                 
          addition, respondent retained the following refunds due the                 
          Doyles to offset their assessed tax liabilities:                            










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