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petition was not extinguished as a result of his
bankruptcy discharge. Secs. 6321 and 6322, I.R.C.,
applied.
Held, further, no exemption to levy applies in
this case.
Held, further, R may proceed with collection by
levy as determined in the “NOTICE OF DETERMINATION
CONCERNING COLLECTION ACTION(S) UNDER SECTION 6320
and/or 6330”.
Santo J. Bonanno, for petitioner.
Robert F. Saal, for respondent.
NIMS, Judge: This case arises from a petition for judicial
review filed in response to a “NOTICE OF DETERMINATION CONCERNING
COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330” (notice of
determination). Unless otherwise indicated, all section
references are to the Internal Revenue Code in effect at all
relevant times.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of the parties, with accompanying exhibits, are
incorporated herein by this reference. At the time the petition
was filed in this case, petitioner resided in Ringwood, New
Jersey.
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