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12153, Request for a Collection Due Process Hearing, with respect
to his 1995 and 1996 years. After the cancellation of two
previously scheduled section 63301 hearings, one was held with
petitioner on February 22, 2002. At that hearing, petitioner
raised only questions concerning the merits of his underlying tax
liabilities, which the Appeals officer advised could not be
considered because petitioner had already had that opportunity
before the Tax Court. The Appeals officer offered petitioner
collection alternatives and provided forms for an offer in
compromise. At the hearing petitioner provided the Appeals
officer with 10 checks, each in the amount of $20.42, which
petitioner had received from the Treasury of the United States
(the Treasury) and wished to have applied to his 1995 liability.
Following the conference with Appeals, petitioner supplied
completed offer-in-compromise forms, and a determination was made
that petitioner had sufficient assets to pay the outstanding 1995
and 1996 tax liabilities in full. Accordingly, a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 concluding that respondent may proceed with
collection of petitioner’s 1995 and 1996 tax liabilities was
mailed to petitioner, and he appealed to this Court.
1 All section references are to the Internal Revenue Code in
effect for the years in issue.
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Last modified: May 25, 2011