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hearing settlement officer determined to delay until after June
24, 2005, the filing of a notice of Federal tax lien with respect
to the Gazis’ unpaid liabilities for 1983 through 1989 in order
to allow Mr. Gazi an opportunity to give the Internal Revenue
Service a mortgage on certain property with respect to such
liabilities in lieu of respondent’s filing a notice of Federal
tax lien.
On June 29, 2005, the revenue officer made the following
entry in the “integrated collection system history transcript”:
Received fax from POA [Ms. Ciraolo] with the property
listings that they will use to secure the mortgage as
an alternative to filing the NFTL. At this time they
are working to obtain title searches and appraisals to
determine the equity in each property. The date given
by Appeals to get this done was 06/24/05 but this is
not possible as the process will take some time.
Extending time through July 10, 2005. [Reproduced
literally.]
On July 20, 2005, the revenue officer spoke with Ms. Ciraolo
and informed her that respondent had decided not to accept from
Mr. Gazi a mortgage on certain property in lieu of respondent’s
filing a notice of Federal tax lien. During that conversation,
the revenue officer also informed Ms. Ciraolo that respondent
would consider an offer by Mr. Gazi to post a bond with respect
to the Gazis’ unpaid liabilities for 1983 through 1989 in lieu of
filing a notice of Federal tax lien.
On July 28, 2005, the Court issued its Memorandum Findings
of Fact and Opinion in the Gazis’ Tax Court case (July 28, 2005
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