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On September 30, 1996, petitioners filed a bankruptcy
petition under Chapter 13 of the United States Bankruptcy Code in
California. On October 15, 1996, the Internal Revenue Service
filed a proof of claim in petitioners’ bankruptcy proceeding
which included $45,814.97 in income tax liabilities plus interest
for the four years. On November 1, 1996, petitioners’ bankruptcy
proceeding was converted from a Chapter 13 to a Chapter 7
bankruptcy proceeding. On March 14, 1997, the bankruptcy court
entered an order of discharge in the petitioners’ bankruptcy
case.
On February 11, 2003, respondent filed a Notice of Federal
Tax Lien with the Los Angeles County Recorder’s Office in
connection with petitioners’ unpaid income tax liabilities for
the four years. On February 14, 2003, respondent issued to
petitioners a Notice of Federal Tax Lien Filing and Your Right to
a Hearing Under IRC 6320 (the notice), which advised petitioners
that a notice of Federal tax lien has been filed with respect to
their unpaid income tax liabilities for the four years, and that
petitioners were entitled to a hearing.
On March 25, 2003, petitioners timely filed Form 12153,
Request for Collection Due Process Hearing. In their request,
petitioners claimed that the tax liabilities for the four years
were discharged in the bankruptcy proceeding.
On December 9, 2003, a face-to-face conference was held
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Last modified: May 25, 2011