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least six months in 1988 and never submitted a new W-4
form since I was on the same job. When I got another
job in July or August 1988 (and subsequent years), I
followed the same protocol. Although on the W-4's for
1988, 1989 and 1990 it states full-time students are
not automatically exempt, it does not tell you the
procedure by which to go by. I still stand by my
belief that I had a right to claim exempt because I was
a full-time student.
Once again, I feel that the amount for an alleged
liability incurred when I was 21-23 years old that is
10-13 years old respectively is still grossly unfair.
In particular since the interest and penalties total
more than the debt claimed I was to pay and I simply
cannot afford it. In addition, the law of the IRS is
that after 6 years (assuming a person has not failed to
report more than 25% of their income) the tax records
of an individual are closed from what I understand.
[Reproduced literally.]
On July 12, 2000, petitioner had an Appeals Office hearing
before Mr. Lawrence. Prior to June 11, 1999, the date of the
receipt by respondent of petitioner’s request for an Appeals
Office hearing, petitioner had had no contact with Mr. Lawrence
with respect to petitioner’s unpaid liability for each of the
years 1987, 1988, 1989, and 1990.
On September 15, 2000, the Appeals Office issued to peti-
tioner a notice of determination with respect to petitioner’s
taxable years 1987, 1988, 1989, 1990, and 1997. That notice of
determination stated in pertinent part as follows:
Issue[s] raised by the taxpayer
* * * * * * *
The taxpayer’s position is that she should not be held
liable for the interest and penalties that have accrued
on the unpaid taxes, for the tax years involved [1987,
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