Robert A. and Nanci M. Spurgin - Page 7




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          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.                                





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