124 T.C. No. 6 UNITED STATES TAX COURT JUANITA AND EMMANUEL KENDRICKS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3430-03L. Filed March 9, 2005. At the conclusion of a collection due process hearing (hearing), R’s Appeals Office (Appeals) determined to proceed by levy to collect unpaid assessments of tax. Ps ask us to review that determination. Among other errors, Ps claim that Appeals erred in not allowing them to raise at the hearing the tax liabilities underlying the unpaid assessments because they had not had the opportunity to dispute those liabilities in a bankruptcy proceeding instituted by them. 1. Held: The bankruptcy proceeding instituted by petitioners afforded them the opportunity to dispute the underlying liabilities within the meaning of sec. 6330(c)(2)(B), I.R.C., and, as a result, Ps were precluded from raising those liabilities during the hearing. 2. Held, further, because Ps neither raised collection alternatives during the hearing nor properly made an offer in compromise, Appeals did not err inPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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