T.C. Memo. 2004-237
UNITED STATES TAX COURT
THEODORE W. BANIS, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13155-02L. Filed October 14, 2004.
P timely petitioned this Court to review R’s
determination to proceed with collection of assessments
against P for 1993-96. After concessions by both
parties, only 1996 remains in issue. P alleges that
his liability for 1996 was paid by the trustee in his
bankruptcy proceeding and that respondent specifically
acknowledges the satisfaction of his 1996 liability in
a “closing letter”. R alleges (1) the trustee’s
payments to R were applied, in their entirety, to 1990-
94, (2) the “closing letter” concerns a proposed
additional amount of tax and related adjustments, which
were dropped on the basis of information provided by P,
and (3) the assessments relating to P’s self-determined
tax liability for 1996 remain unpaid.
Held: On the basis of the evidence, the
determination by R’s Appeals officer to proceed with
collection of the assessments against P for 1996 is
sustained.
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