122 T.C. No. 16 UNITED STATES TAX COURT GREGORY IANNONE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 17412-02L. Filed April 19, 2004. P filed a timely petition for judicial review pursuant to sec. 6330(d)(1)(A), I.R.C., in response to a notice of determination by R to proceed with collection of assessed tax liabilities for 1987, 1989, and 1991. Subsequently, the Court granted respondent’s Motion to Dismiss for Lack of Jurisdiction and to Strike as to Taxable Year 1987. Held: For the purpose of this collection proceeding, the Appeals officer agreed to assume that petitioner’s 1989 and 1991 tax liabilities were discharged in bankruptcy. We will not remand this case for a clearer articulation of the Appeals officer’s determination relating to petitioner’s bankruptcy discharge. Held, further, the existing Federal tax lien that attached to P’s property when he filed his bankruptcyPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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