Corrie Miles - Page 4




                                        - 4 -                                         
          Court determined that petitioner’s 1996, 1997, and 1998 tax                 
          liabilities would be discharged upon the entry of an order                  
          granting petitioner a discharge in her bankruptcy case.  On                 
          August 25, 2003, the Bankruptcy Court entered an order of                   
          discharge in petitioner’s bankruptcy case pursuant to 11 U.S.C.             
          section 727 (2000).                                                         
          Petitioner’s Individual Retirement Account                                  
               On the date she filed her chapter 7 bankruptcy petition,               
          petitioner owned an individual retirement account (IRA) worth               
          $142,545.90.                                                                
          Respondent’s Collection Efforts                                             
               On December 4, 2003, Revenue Officer Cindy Alexander (Ms.              
          Alexander) was assigned to investigate enforcement of the Federal           
          tax liens with respect to petitioner’s 1997 and 1998 tax                    
          liabilities.  Ms. Alexander determined that the Federal tax liens           
          for 1997 and 1998 attached to petitioner’s IRA to the extent of             
          its value of $142,545.90 on the date petitioner filed her                   
          petition in her bankruptcy case.  On March 18, 2004, Ms.                    
          Alexander sent petitioner a Final Notice--Notice of Intent to               
          Levy and Notice of Your Right To a Hearing with regard to                   
          petitioner’s 1997 and 1998 tax liabilities (notice of intent to             
          levy).  On April 14, 2004, petitioner sent to respondent a Form             
          12153, Request for a Collection Due Process Hearing.  In the Form           
          12153, petitioner stated that she disagreed with the collection             







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  Next 

Last modified: November 10, 2007