- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007