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response to petitioner’s June 19, 1990 letter. In that letter,
respondent stated: “We are looking into the matter you brought
to our attention; however, additional research is needed before
we can give you a final answer. No further action is required of
you at this time. We should have a response for you within 30
days from the date of this letter.”
On August 9, 1990, respondent sent petitioner a second
letter in response to petitioner’s June 19, 1990 letter. In that
letter, respondent stated:
Thank you for your reply dated June 19, 1990, to our
inquiry about your Form 1040 for the tax period(s)
shown above [petitioner’s taxable years 1987, 1988, and
1989]. We are looking into the matter and will answer
you more fully within 45 days from the date of this
letter.
On November 12, 1990, respondent sent petitioner a notice of
intent to levy with respect to petitioner’s unpaid liability for
each of the years 1987, 1988, and 1989.
On a date not disclosed by the record after petitioner sent
petitioner’s June 19, 1990 letter to respondent and before July
29, 1991, petitioner again informed respondent that she was
unable to pay in full her liability for each of the years 1987,
1988, 1989, as well as 1990. On July 29, 1991, respondent sent
petitioner a letter with respect to petitioner’s unpaid liability
for each of the years 1987, 1988, 1989, and 1990. In that
letter, respondent stated:
You told us recently that you cannot pay your
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