William J. McCorkle - Page 9

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          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 order           






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