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time were the 1997 bankruptcy sale proceeds commingled with other
funds. On October 6, 1999, Notices of Federal Tax Lien were
filed against Barbara Drake and petitioner with respect to their
1994, 1995, and 1997 tax years.
On January 10, 2000, respondent issued computer-generated
notices of outstanding income tax liabilities to Barbara Drake
and petitioner. On January 14, 2000, respondent received from
Barbara Drake and petitioner a Form 433-A, Collection Information
Statement for Individuals (collection information statement). On
the collection information statement, no response was provided to
the question of whether assets had recently been sold or
otherwise transferred for less than their full value.
III. The Initial Section 6330 Hearing
On July 19, 2000, respondent mailed to Barbara Drake and
petitioner a Final Notice, Notice of Intent to Levy and Notice of
Your Right to a Hearing, with respect to their 1991, 1992, 1994,
1995, and 1997 tax years. The notice asserted an unpaid tax of
$121,478.17 and penalties and interest of $88,607.27. Pursuant
to a power of attorney, Timothy J. Burke (Mr. Burke) timely
requested a section 6330 hearing on behalf of Barbara Drake and
petitioner. Subsequently, on behalf of Barbara Drake, Mr. Burke
submitted a Form 8857, requesting relief from joint and several
3(...continued)
aforementioned stipulation, the Court finds that petitioner
gratuitously transferred the entire $151,139.74 to his sons.
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