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disbursements of, inter alia, $299,850 to Triple R Construction,
$90,169.19 to GE Elfun Account, $24,000 to a Jeep dealership,
$23,857.22 to MB, $16,600 to John Lawncare, $15,000 to Best
Prices, $12,014.04 to Mudricks, as well as other disbursements of
thousands of dollars to, inter alia, each of Aquarius Pools and
Spas, Reese’s Delivery Services, Thomaston Oil, Soundworks and
Security, Benders, and Angelo’s.
On April 7, 2003, in response to the March 13, 2003 letter,
petitioner also sent a letter to the settlement officer which
stated in pertinent part:
Below is my statement detailing my proposed alternative
to the filed Notice of Federal Tax Lien.
I no longer own the property at 919 Wilcoxson Avenue,
Stratford, CT. It was deeded to my son and daughter-
in-law per the attached Quit Claim Deed.
On June 25, 2003, the settlement officer held an Appeals
Office hearing with petitioner with respect to the notice of
lien. During that hearing, the settlement officer discussed
possible collection alternatives with petitioner, including
posting a bond, substituting collateral, or paying in full
petitioner’s unpaid liability for 2000. In addition, the settle-
ment officer considered whether there were grounds under section
6323(j) to withdraw the notice of lien. At no time in connection
with the Appeals Office hearing did petitioner submit an offer-
in-compromise to the settlement officer or request an installment
agreement. Petitioner did not dispute the existence or the
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