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 bankruptcy
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