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action proposed in respondent’s notice of intent to levy and
requested a hearing pursuant to section 6330(b).
Petitioner’s Section 6330 Hearing
Petitioner’s section 6330 hearing was assigned to Settlement
Officer Cynthia Chadwell (Settlement Officer Chadwell).
Petitioner’s section 6330 hearing consisted of phone calls and a
written correspondence between Settlement Officer Chadwell and
petitioner’s representatives that occurred between March and July
of 1998. As discussed infra, petitioner raised two arguments
during the hearing. Petitioner argued that respondent
erroneously determined that the Federal tax liens continued to be
valid against petitioner’s interest in her IRA after her
discharge from personal liability on the 1997 and 1998 income tax
liabilities in her chapter 7 bankruptcy case. Petitioner also
argued that respondent erroneously determined that the Federal
tax liens remained valid after petitioner allegedly transferred
the funds in her IRA into a pension plan administered by
petitioner’s new employer. Settlement Officer Chadwell
determined to proceed with the proposed levy, and respondent
issued to petitioner a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 on July 29,
2005.
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Last modified: November 10, 2007