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document need be provided to a taxpayer at an administrative
hearing conducted under section 6330, and that a Form 4340 (such
as those included in this record) and other transcripts of
account satisfy the verification requirements of section
6330(c)(1). See Roberts v. Commissioner, 118 T.C. 365, 371 n.10
(2002), affd. 329 F.3d 1224 (11th Cir. 2003); Nestor v.
Commissioner, 118 T.C. 162, 166 (2002); Lunsford v. Commissioner,
117 T.C. 183 (2001).
Petitioner also asserted that his tax liabilities for 1983
and 1993 to 1995 were discharged by the bankruptcy court. The
Court has jurisdiction in a collection review proceeding to
determine whether the unpaid tax liabilities in dispute were
discharged in a bankruptcy proceeding. Washington v.
Commissioner, 120 T.C. 114, 120-121 (2003).
The record reflects that, on December 6, 1996, petitioner
voluntarily filed a bankruptcy petition under chapter 7 of the
Bankruptcy Code. Although the bankruptcy court issued an order
of discharge in that case, petitioner’s unpaid tax liabilities
for 1983 and 1993 to 1995 were not discharged because petitioner
failed to file tax returns for those years. See 11 U.S.C. sec.
523(a)(1)(B)(i) (2000); Swanson v. Commissioner, 121 T.C. 111,
124-125 (2003).
Petitioner's assertion that respondent's motion should be
denied on the ground respondent failed to demonstrate that
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