Robert A. and Nanci M. Spurgin - Page 7
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Resolution Office in order to “better serve you in clearing up
the problem you are having with your taxes.”4 Linda Caballero, a
problem resolution technician, was assigned to petitioners’ case.
Ms. Caballero requested that petitioners complete Form 433-A,
Collection Information Statement for Individuals, and Form 433-B,
Collection Information Statement for Businesses. Petitioners
completed Forms 433-A and 433-B and forwarded the forms to Ms.
After reviewing Forms 433-A and 433-B and accepting the
information therein at face value, Ms. Caballero informed
petitioners as follows:
This letter confirms our telephone conversation on 12-
21-95 concerning your 1993/1040 tax liability. Based
on the financial information statement you submitted, I
have determined that you are currently unable to make
payments toward your tax liability. Therefore, your
account is being placed in a currently uncollectible
status. * * * this suspension is temporary and
interest and/or penalties will continue to accrue until
the tax is paid in full. In addition, * * * a Federal
Tax lien is being filed to protect the government’s
interest in this matter.
1When a taxpayer’s account is placed in uncollectible
status, the Commissioner does not attempt to enforce collection
against the taxpayer.
2On Feb. 21, 1996, respondent filed a Notice of Federal Tax
Lien with the County Recorder for Orange County in Santa Ana,
California. The lien was released on Sept. 14, 1997, shortly
4 On Mar. 8, 1995, shortly after petitioners’ account had
been transferred to the Problem Resolution Office, respondent
served a notice of levy on First Interstate Bank of California.
The levy was released on Mar. 20, 1995, presumably because
petitioners’ case had been transferred to the Problem Resolution
Office, without the collection of any funds.
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