Robert William Woods - Page 6

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               At trial, petitioner’s only argument, raised for the first             
          time, was that the bankruptcy court’s July 27, 2004, order                  
          discharged his tax liabilities.                                             
                                     Discussion                                       
               The issue we must decide is whether the bankruptcy court’s             
          July 27, 2004, order forecloses respondent from collecting                  
          petitioner’s tax liabilities for the 1988, 1989, 1990, 1991,                
          1993, 1995, 1996, and 1997 taxable years.  Petitioner did not               
          raise the issue of his bankruptcy discharge during the section              
          6330 Appeals hearing (Appeals hearing) because he did not file              
          for bankruptcy until after filing his petition to this Court for            
          review of respondent’s determination to proceed with collection.            
               Before we address the issue of the bankruptcy discharge, we            
          briefly address petitioner’s position at the Appeals hearing, in            
          his petition to this Court, and throughout the administrative               
          process before the Internal Revenue Service.  Section 6330                  
          provides that no levy may be made on any property or right to               
          property of a person unless the Secretary first notifies the                
          person in writing of the right to a hearing before the Appeals              
          Office.  Section 6330(c)(1) provides that the Appeals officer               
          must verify at the hearing that the applicable laws and                     
          administrative procedures have been followed.  At the hearing,              
          the person may raise any relevant issues relating to the unpaid             
          tax or the proposed levy, including appropriate spousal defenses,           






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