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B. Collection Proceedings
As noted above, the estate appealed this Court’s decisions
in the Kanter deficiency cases to the Court of Appeals for the
Seventh Circuit. The estate did not post a bond under section
7485 to stay the assessment or collection of the tax liabilities
in dispute during the pendency of the appeals. Consequently,
respondent entered assessments against the estate for the
deficiencies, additions to tax, and increased interest set forth
in the Court’s decisions in the Kanter deficiency cases.
On January 13, 2003, respondent issued to the estate a Final
Notice--Notice of Federal Tax Lien Filing and of Your Right to a
Hearing regarding the estate’s unpaid Federal income taxes for
1978 to 1984, 1986, and 1991.6 The estate submitted to
respondent’s Office of Appeals (Appeals Office) a timely request
for an administrative hearing under section 6320.7
On August 4, 2005, respondent’s Appeals Office issued to the
estate a Notice of Determination Concerning Collection Action(s).
The Appeals Office determined (1) the liens were properly filed,
(2) the estate’s offer-in-compromise based on doubt as to
6 The taxable year 1991 was not the subject of any of the
notices of deficiency in dispute in the Kanter deficiency cases.
The record suggests that respondent entered an assessment against
the estate for 1991 based upon the disposition of a so-called
TEFRA partnership proceeding for 1991.
7 The record in this case does not include copies of the
Notice(s) of Federal Tax Lien that would have precipitated the
issuance of the Final Notice--Notice of Federal Tax Lien Filing.
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