Steven G. Orr - Page 3

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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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