- 16 - 6015.8 Id. at 160. Consequently, rather than deciding Barbara Drake’s section 6015 request, the bankruptcy court decided that the “interests of justice are better served by allowing * * * [Barbara Drake’s] appeal to proceed at the IRS.” Id. On May 16, 2006, the bankruptcy court denied a motion for reconsideration filed by the United States. On May 30, 2006, the United States filed a Notice of Appeal to the U.S. District Court for the District of Massachusetts. VIII. The Section 6330 Hearing on Remand On October 17, 2005, in accordance with our holding in Drake I, we ordered respondent to offer petitioner a new section 6330 hearing with an independent Appeals officer on a date no later than November 10, 2005. In addition, we ordered the parties to each file with the Court a status report no later than January 6, 2006. A. Proceedings Before Appeals Officer Kramer On behalf of petitioner, Mr. Burke met with Appeals Officer Linda Kramer at the IRS Appeals Office in Boston, Massachusetts, on November 4, 2005. Appeals Officer Kramer had no prior involvement with petitioner and had received no communication relating to the credibility of petitioner or petitioner’s 8In addition, the bankruptcy court noted that there were no assets to be administered and the property subject to the IRS lien was no longer the property of the bankruptcy estate. In re Drake, 336 Bankr. at 160.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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