Corrie Miles - Page 5




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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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