- 2 - The decisions to be entered are not reviewable by any other court, and this opinion should not be cited as authority. Respondent sent separately to petitioner Josef Lah (Mr. Lah) and petitioner Marie Lah (Mrs. Lah) (collectively, petitioners) a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination).2 The issue for decision is whether respondent may proceed with the proposed collection activities relating to 1990, 1991, 1992, and 1993 (years in issue). Background Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time they filed the petitions, petitioners resided in Chardon, Ohio. Petitioners filed a chapter 11 bankruptcy petition on November 25, 1985. The case was subsequently converted to a chapter 7 proceeding. On March 5, 1986, respondent assessed a section 6672 trust fund recovery penalty (TFRP) against each petitioner of more than $40,000.3 The TFRP resulted from the failure to withhold and pay over income and Federal Insurance Contribution Act taxes for 2 Petitioners’ cases were consolidated for purposes of trial, briefing, and opinion. 3 Respondent assessed $43,652 against Mr. Lah and $45,485 against Mrs. Lah.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011