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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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Last modified: November 10, 2007