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On June 11, 1999, respondent received petitioner’s request
for an Appeals Office hearing with respect to her unpaid liabil-
ity for each of the years 1987, 1988, 1989, and 1990. In that
request, petitioner stated:
I do not agree with the Notice of Levy/Seizure because
of the circumstances in which were done to determine
the tax liability. For several years, I have written
and telephoned the IRS to try to set up a meeting to
try and remedy this situation, to no avail.
The taxes incurred are when I was a full-time student
and I filled out the W-4 form according to the instruc-
tions listed under number 7 which states “I claim
exemption from withholding for...and I certify that I
meet BOTH of the following conditions for exemp-
tion:...” Since that time the form has been changed,
but when I filled them out for the years of collection
one of the conditions were if you were a full-time
student.
I now know, through investigation, that if a person
made over a certain income they could not be exempt.
However, at the time this was not made clear by my
employer or on the W-4 form. It was almost like a set-
up for students and I truly do not feel I should be
held liable for the amount of $8,718.39 that is being
stated I owe.
Because this has been a detriment to me for a very long
time, I would be willing to pay the assessed balance
charges, just so that I may get this behind me. How-
ever, I do not seem it just nor proper to charge me
with Statutory Additions or to penalize me by seizing
any property of mines which would not equal the amount
owed. I am a single mother and any penalization would
be a severe hardship for me.
I welcome an opportunity to finally review this with an
IRS representative in person at the earliest possible
time to set-up a payment plan. [Reproduced literally.]
On October 5, 1999, Appeals Officer Martin D. Fried sent
petitioner a letter indicating that he had received petitioner’s
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