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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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