- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007