- 3 - 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 heldPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011