- 7 - 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. Caballero. 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.[1] * * * 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.[2] 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011