Michael V. Severo and Georgina C. Severo - Page 1

                                   129 T.C. No. 17                                    

                               UNITED STATES TAX COURT                                

              MICHAEL V. SEVERO AND GEORGINA C. SEVERO, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6346-06L.     Filed November 15, 2007.                      

                    With the late filing of their 1990 joint Federal                  
               income tax return, petitioners failed to pay most of                   
               the $63,499 taxes reported due.  In 1994, petitioners                  
               filed a bankruptcy petition.  In 1998, petitioners                     
               received a bankruptcy discharge order.                                 
                    In 2004, respondent levied against petitioners’                   
               $196 California income tax refund and notified                         
               petitioners of their appeal rights with regard thereto.                
               Petitioners did not file an appeal.                                    
                    In 2005, respondent mailed to petitioners a notice                
               of Federal tax lien filing (NFTL) and a notice of                      
               intent to make a second levy.                                          
                    Petitioners requested an Appeals Office collection                
               hearing relating both to respondent’s NFTL and to                      
               respondent’s notice of intent to make a second levy in                 
               which petitioners claimed that the 1998 bankruptcy                     
               discharge order and the expiration of the collection                   

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