Snyder v. Internal Revenue Service

MEMORANDUM

LEGG, Chief Judge.

I. Introduction

Because this case is complicated, a brief introduction is in order. This is a bankruptcy appeal that calls into question whether the Internal Revenue Service (“IRS” or “Service”) followed certain technical procedures mandated by Congress for assessing income taxes against Richard and Marion Snyder and using its lien authority to collect the money due. On September 27, 2005, the Court held a hearing in which counsel for the IRS, Gregory S. Hrebiniak, Esquire, and Mr. Snyder participated. Having heard from both parties, the Court concludes that the IRS…