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tioner filed her return for 1989, and on May 18, 1990, she filed
her return for each of the years 1987 and 1988. In June 1990,
respondent timely assessed petitioner for her unpaid liability
for each of the years 1987, 1988, and 1989. In petitioner’s June
19, 1990 letter and again sometime thereafter, petitioner in-
formed respondent that she was unable to pay in full her unpaid
liability for each of those years, which prompted respondent to
send petitioner Form 433-F on July 29, 1991.8 Although prior to
trial petitioner claimed that she completed Form 433-F that
respondent sent to her, respondent has no record of having
received that form. In December 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 and classi-
fied each such liability as “currently not collectible” because
respondent was unable to locate petitioner. In May and June
1998, respectively, respondent sent petitioner notices of balance
due and notices of intent to levy with respect to her unpaid
liability for each of the years 1987, 1988, and 1989, to which
7(...continued)
1990 and (2) separate notices of balance due with respect to her
unpaid liability for 1988 and 1989 in June 1990 as well as in
July 1990.
8Although petitioner claimed in certain letters that she
sent to respondent that she was unable to pay in full her unpaid
liability for each of the years 1987, 1988, and 1989, petitioner
did not contend in her petition, at trial, or on brief that she
was not able to pay that liability for each such year.
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