Don Mahoney - Page 5




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          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).                                                              





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