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proceeding, the bankruptcy court discharged Carole’s 1987 tax
liability.
C. Notice of Federal Tax Lien
On September 8, 2000, respondent mailed to petitioner and
Carole a Notice of Federal Tax Lien Filing and Your Right to a
Hearing Under I.R.C. � 6320 regarding the 1987 tax liability.
D. Appeals Office Hearings
On September 25, 2000, petitioner and Carole timely filed a
Form 12153, Request for a Collection Due Process Hearing. On
January 25 and March 19, 2002, petitioner met with Appeals
Officer Ronald Szalkowski (AO Szalkowski) and discussed the 1987
tax liability and the possibility of entering into an installment
agreement. AO Szalkowski subsequently prepared an installment
agreement and forwarded it to petitioner, who rejected it because
it reflected a greater balance due than he had anticipated.
E. Notice of Determination
In a Notice of Determination Concerning Collection Action(s)
Under Section 6320 and/or 6330, dated August 16, 2002, respondent
determined that the legal, administrative, and procedural
requirements for proceeding with collection by lien of
petitioner’s and Carole’s 1987 income tax had been met.
On September 17, 2002, petitioner and Carole timely filed a
petition in this Court. Respondent moved to dismiss this case as
to Carole because her underlying tax liability had been
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Last modified: May 25, 2011