- 5 - from year(s) prior to 1994,4 which petitioner contended resulted from a discharge of these liabilities in a separate bankruptcy case (i.e., a case other than petitioner’s 1993 bankruptcy case), to reduce petitioner’s liabilities for the years in issue. Third, petitioner expressed his intent to submit an offer-in- compromise with regard to his outstanding tax liabilities for the years in issue; however, he did not submit an offer-in-compromise as part of his section 6330 hearing. On July 13, 2005, after reviewing the correspondence and documents that petitioner submitted, respondent issued to petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. Settlement Officer Clark determined respondent did not erroneously apply installment agreement payments to petitioner’s outstanding 1985 tax liability because, among other reasons, respondent was not required by an installment agreement, or otherwise, to apply petitioner’s payments solely to his outstanding liabilities for the years in issue. Furthermore, Settlement Officer Clark was unable to find any record of a separate bankruptcy case (i.e., a case other than petitioner’s 1993 bankruptcy case). 4 At various times during his sec. 6330 hearing, petitioner identified the prior year(s) as (1) 1985 through 1988, (2) 1987 through 1988, or (3) 1984 (on brief, however, petitioner referred only to 1984).Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007