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nominee liens and his right to a hearing (hearing notice). At
the time he received the hearing notice, petitioner was receiving
chemotherapy treatments.
On May 9, 2001, Mr. Mahalaris rejected petitioner’s OIC.
Section 6330 Hearing and Determination
On May 17, 2001, petitioner timely filed a Form 12153,
Request for a Collection Due Process Hearing, regarding his
1986,5 1987, 1988, 1989, and 1992 tax years (hearing request).
In the hearing request, petitioner: Disputed the nominee status
of the trusts and corporation; noted that the IRS had placed
petitioner in uncollectable status; disputed the amount
respondent claimed petitioner owed because he lacked an
opportunity to dispute the amount earlier; and noted that the $5
million figure listed on the 1989 return was not correct. On
July 20, 2001, petitioner’s case was assigned to Settlement
Officer Michael G. Blais. On January 14, 2002, Mr. Blais made
the following entry into his case activity record:
“Notwithstanding nominee issues there still appears to be a
reasonable collection potential figure far below the full
balance”.
5 The hearing request lists “12/31/96” as one of the tax
periods in issue; however, this appears to be either a
typographical error that respondent treated as referring to 1986
or based upon respondent’s error contained in the nominee liens.
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Last modified: May 25, 2011