- 9 -
The notice of determination in this case was issued on
January 7, 2005. The notice of determination reflected that the
unpaid estate tax liability was $1,650,674.72, as calculated
through March 10, 2004. An attachment to the notice of
determination stated in relevant part:
The four basic collection alternatives to avoid
enforced collection action are full payment,
installment agreement, Offer in Compromise, or closing
the account as “Currently Not Collectible” based on
financial hardship. Outside of full payment,
procedures for the other collection alternatives
require that the entity file any outstanding tax
returns and that the entity submit a full financial
statement and verification information for analysis.
Neither of these two requirements has been fulfilled by
the estate.
* * * * * * *
At the point the Notice of Intent to Levy was mailed,
the value of the estate had dwindled from a reported $7
million in January 2000 to $338,720.19 as reported on
the Form 433-B financial statement signed by Mr.
MacQuarrie on April 13, 2004. No payments of any
amount have been remitted toward the assessments of
January 24, 2002. Without full financial disclosure
and full compliance with outstanding returns, no
collection alternative is available outside of full
payment.
* * * * * * *
The class action lawsuits have not been initiated by
the estate. Therefore there should be no
administrative expenses necessary to monitor them. The
only known administrative expenses accruing at this
time are for return preparation and Collection/Appeals
representation.
* * * * * * *
* * * The enforcement action taken by the Collection
Division in issuing the Notice was appropriate and
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: November 10, 2007