Simone Joye - Page 10




                                       - 10 -                                         
          case for consideration and that he would contact petitioner to              
          schedule an Appeals Office hearing.  On February 28, 2000,                  
          Appeals Officer Federico Lawrence (Mr. Lawrence) sent petitioner            
          a letter indicating that he had received petitioner’s case for              
          consideration and that he would contact petitioner to schedule an           
          Appeals Office hearing.                                                     
               On June 20, 2000, Mr. Lawrence sent a letter to petitioner             
          (Mr. Lawrence’s June 20, 2000 letter), in which he stated:                  
               Attached, [sic] for your information is a copy of Form                 
               W-4 for the taxable year 1988.  Line 7 of the document                 
               states as follow[s]:                                                   
               “Are you a full time student? (Note:  Full-time stu-                   
               dents are not automatically exempt.)”                                  
               I was not able to locate a copy of the Form W-4 for                    
               1987 but I assumed it would be identical to the 1988 W-                
               4 Form.  Also, 1988 was the year you incurred largest                  
               liability.  Our records show the outstanding balance                   
               for taxable year 1988 to be $5,019.81, as of May 1999.                 
               This amount includes accrued interest and penalties.                   
               Line 6 of Form W-4, Employee’s Withholding Allowance Certif-           
          icate (Form W-4), for 1987, which, according to Mr. Lawrence’s              
          June 20, 2000 letter, he was unable to locate, provided:                    
          6 I claim exemption from withholding because (see Step 2 above              
          and check boxes below that apply):                                          
          a G  Last year I did not owe any Federal income tax and had a               
          right to a full refund of ALL income tax withheld, AND                      
          b G  This year I do not expect to owe any Federal income tax                
          and expect to have a right to a full refund of ALL income                   
          tax withheld.  If both a and b apply, enter the year    Year                
          effective and “EXEMPT” here . . . <                     19                  
          c If you entered “EXEMPT” on line 6b, are you a full-time                   
          student? . . . . . . . . . . . . . . . . . . . . . . .  GYes GNo            
               The instructions for completing line 6 of Form W-4 for 1987            






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