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taxes in full. Therefore, you must complete the en-
closed Form 433F, Collection Information Statement.
* * * * * * *
If you do not return the above documents within 7
days from the date of this letter, we will begin en-
forcement actions. We expect you to pay as much as
possible at the time you send in your statements. * * *
Respondent has no record of having received Form 433-F, Collec-
tion Information Statement (Form 433-F), from petitioner.
On December 15, 1995, respondent filed a notice of Federal
tax lien against petitioner with respect to her unpaid liability
for each of the years 1987, 1988, and 1989. On December 26,
1995, respondent classified petitioner’s unpaid liability for
each of the years 1987, 1988, and 1989 as “currently not collect-
ible” because respondent was unable to locate petitioner.
On May 18, 1998, respondent sent petitioner a separate
notice of balance due with respect to petitioner’s unpaid liabil-
ity for each of the years 1987, 1988, and 1989. On June 22,
1998, respondent sent petitioner a separate notice of intent to
levy with respect to each of those unpaid liabilities.
On July 8, 1998, petitioner sent respondent a letter in
response to the three notices of balance due that respondent sent
to petitioner on May 18, 1998. In that letter, petitioner
stated:
On June 19, 1990 I sent a letter to the IRS regarding
taxes for 1987, 1988, and 1989 (copy enclosed). It was
clearly stated on the W-4 form if you were a full-time
student you were instructed to write in EXEMPT from
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