- 9 - Section 6320 and/or 6330 (notice of determination) denying petitioner any relief. The notice of determination contained a summary of the Appeals Office’s determination, which was further detailed in an attachment authored by the settlement officer. In support of sustaining the filing of the NFTL, the settlement officer determined that the $2 million remittance had been subject to a criminal forfeiture proceeding and that petitioner was not entitled to rely on those funds to satisfy the 1996 tax liability. The settlement officer also determined that the filing of the NFTL was appropriate and no circumstances existed to either release or withdraw it. He further determined that petitioner had admitted to his inability to pay the liability, but petitioner had failed to request any collection alternatives or to provide any information from which collection alternatives could be considered. The settlement officer sustained the filing of the NFTL. The Amended Petition Petitioner filed a petition and an amended petition. In the amended petition, petitioner states that, for 1996: “[He] paid $2,000,000.00 estimated tax payment to the IRS, but never did actually file a return.” He adds: “The Department of the Treasury in a manual refund check refunded this $2,000,000.00 to the U.S. Marshall’s service pursuant to a court order for forfeiture.” He claims: “This refund based upon the court orderPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011