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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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