BANKRUPTCY CODE CASES: Priorities: Income taxes

ID: CCA_2011120609101250 Number: 201152017
Release Date: 12/30/2011
Office: ---
UILC: 09.32.06-00
From: ---
Sent: Tuesday, December 06, 2011 9:10:15 AM
To: ---
Cc: ---
Subject: RE: Discharge and Tolling Argument due to CDP?
BAPCPA amended section 507(a)(8) to suspend the time periods for determining priority status for the period that collection is prohibited by, inter alia, a collection due process hearing and appeals (plus 90 days). Your case, however, involves a CDP lien hearing. IRC 6330(e)(1) only prohibits levy if a proposed levy is the basis of the CDP hearing. ------Please call me if you want to discuss.