Sam E. Scott - Page 7




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               Appeals Officer Grantham concluded that petitioner’s net               
          worth was sufficient to satisfy the outstanding 1991 tax                    
          liability mainly due to the $308,000 equity in a retirement                 
          account, which was subject to loans of $36,000.  The day after              
          the hearing, Appeals Officer Grantham spoke with Revenue Officer            
          McCullough to make arrangements for a possible levy on                      
          petitioner’s retirement account.                                            
               On November 19, 2004, Appeals Officer Grantham received, by            
          facsimile, a letter with an attachment from petitioner                      
          supplementing the matters discussed at the November 16, 2004,               
          hearing.  In the November 19, 2004, facsimile, petitioner                   
          reiterated his health-related difficulties, and he also pointed             
          out that the tax year involved was 1991 so that 13 years of                 
          interest had accrued which represented 75 percent of the                    
          outstanding balance due.  Petitioner also emphasized that he had            
          a good record as a taxpayer during the past 43 years and that               
          cutting off alternative methods for resolution was not                      
          appropriate.  Petitioner advanced Mississippi law in support of             
          his position that his wife had a right to occupy the “marital               
          domicile”, and the filing of a lien would impinge on that right             
          and also lessen the value of the realty without providing                   
          respondent with additional opportunities to collect.  Petitioner            
          also complained that respondent had “appropriated” joint tax                
          refunds to satisfy part of his individual 1991 tax liability.               






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