- 3 - 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.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011