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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
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Last modified: November 10, 2007