- 6 - C. The Collection Process By letter dated July 14, 1994, petitioner acknowledged receipt of respondent’s notice dated June 13, 1994, requesting payment of petitioners’ outstanding tax liability. Petitioner stated that he was “unable to pay the full amount at this time” and that he “would like to explore the opportunity of paying the tax in installments or some other mutually agreeable alternative.” By letter dated September 2, 1994, respondent replied to petitioner’s aforementioned letter, stating in part as follows: Because of the amount you still owe on your current installment agreement, we need to review your financial condition. Please complete the enclosed Form 433-F, Collection Information Statement, and return it within 10 days. Whether petitioners ever returned Form 433-F to respondent is not established by the record, nor is there any indication that the parties ever had any further discussion regarding an installment agreement for the taxable year 1993. By notices dated October 17, 1994, November 21, 1994, and December 26, 1994, respondent continued to advise petitioners that payment of their 1993 tax liability was overdue. Indeed, the third such notice advised petitioners of respondent’s intent to levy if petitioners failed to pay their tax liability. By letter dated February 22, 1995, petitioners were advised that their case had been transferred to respondent’s ProblemPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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