Robert A. and Nanci M. Spurgin - Page 6




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          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 Problem                






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