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that return, and they did not pay any tax at that time.
On June 12, 1989, respondent assessed $6,893 with respect to
the taxable year 1987 of Ms. Collier and Mr. Collier. Respondent
applied $2,967 of tax withheld against that assessment, which
left $3,926 unpaid.
Sometime after June 12, 1989, and before October 1991,
respondent placed a lien on a joint bank account of Ms. Collier
and Mr. Collier with respect to the unpaid assessment for their
taxable year 1987, and Ms. Collier was aware of that lien. In
October 1991, Ms. Collier and Mr. Collier entered into an in-
stallment agreement (1991 installment agreement) with respect to
that unpaid assessment under which they made payments until June
22, 1992, that respondent applied to that assessment. After June
22, 1992, Ms. Collier ceased making installment payments under
the 1991 installment agreement. Mr. Collier continued to make
installment payments under the 1991 installment agreement until
December 1996, when all payments ceased.
In separate notices dated March 25, 1996, May 12, 1997, May
11, 1998, and April 26, 1999 (April 26, 1999 notice) and ad-
dressed to Ms. Collier and Mr. Collier, respondent informed them
that respondent had applied Ms. Collier’s overpayments of tax for
1995, 1996, 1997, and 1998 in the amounts of $26, $946, $725, and
$107, respectively, against the unpaid assessment for 1987. The
April 26, 1999 notice indicated that respondent’s application of
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