Mitchell F. Skrizowski - Page 10

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          uncovered.”  The Appeals case memorandum concluded:  “Hazards to            
          the governments’ [sic] position appear to exist and there appears           
          to be some grounds for settlement * * *  Any percentage based               
          settlement is clearly beyond the reach of the taxpayer based on             
          the total balance of tax due and his relative inability to pay.”            
               On May 9, 2002, respondent issued a Notice of Determination            
          Concerning Collection Action(s) Under Section 6320 and/or 6330 to           
          petitioner regarding his 1986, 1987, 1988, 1989, and 1992 tax               
          years (notice of determination).  In the notice of determination,           
          respondent determined that the liens filed on or about April 9,             
          2001,6 were appropriate and “will remain in full force and effect           
          until satisfied or unenforceable by law.”                                   
               In discussing the OIC as a collection alternative, the                 
          attachment to the notice of determination (the attachment) noted:           
          “While it appears clear that the taxpayer does not have the                 
          ability to liquidate the full amount of $7,000,000 a reasonable             
          amount could not be calculated” and “additional investigation is            
          required to determine an acceptable offer amount.”  The                     
          attachment further noted that the OIC was returned to the                   
          compliance function for additional research and calculation.  The           
          attachment also stated that petitioner disputed the $5 million              
          figure listed on the 1989 return, respondent had previously coded           


               6  It is unclear why the date was listed as Apr. 9, 2001,              
          instead of Apr. 17, 2001.                                                   





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