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The Internal Revenue Service (IRS) issued to the Defense
Accounting Office a Notice of Levy on Wages, Salary, and Other
Income, Form 668-W(c) (the notice of levy), dated April 9, 1998,
and signed by Revenue Officer Barbara Whalen (Revenue Officer
Whalen), seeking to garnish petitioner’s wages. The notice of levy
showed that petitioner and Mr. Washington were liable for unpaid
taxes and additions totaling $70,305.23, of which $809.01 of unpaid
tax and $4,557.27 of statutory additions related to 1989. The
remaining amount was attributable to 1991 ($3,052.21), 1992
($32,255.95), 1993 ($25,578.40), and a civil penalty for 1988
($4,052.39). Mr. Washington’s name and address were typed below
“Name and Address of Taxpayer” on the notice of levy. However, his
name and address were crossed out, and petitioner’s name and
address were inserted.
On May 7, 1998, petitioner received a letter from the Defense
Finance and Accounting Service informing her that another notice of
levy had been issued on petitioner’s wages. The letter stated that
her wages would be subject to garnishment until the $70,305 debt
was collected. Petitioner was instructed to complete and return
parts 3 and 4 of the notice of levy. She was informed that failure
to do so would result in her receiving a biweekly check in the
amount of $240.38 (the personal exemption amount), with the
remainder (approximately $400) being forwarded to the IRS.
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Last modified: May 25, 2011