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wrote respondent a letter, dated July 21, 1989, and signed by
Frank, stating “we just don’t have the money to pay our taxes.
* * * We would like to make some kind of payment agreements.”
In August 1990 (after petitioner had moved to California),
respondent determined that Frank’s income was insufficient to
fund a payment arrangement.2 Respondent classified the 1988
liability as uncollectible.
Collection Action on the 1988 Liability
After 1988, petitioner filed her Federal income tax returns
using a Greenfield, California, address.3 On her 1989 return,
petitioner claimed a $335 refund. On her 1993 return, she
claimed a $1,083 refund.4 In each instance, respondent applied
the claimed refund to the unpaid 1988 liability. In each
instance, petitioner received notification from respondent,
shortly after filing her return, that the refund had been applied
2 The record is unclear as to whether respondent considered
petitioner’s wage income or other assets in denying the request
for a payment arrangement.
3 For 1989 and 1990, petitioner claimed a filing status of
married filing separately. For subsequent years, she claimed a
filing status of single.
4 On her Federal income tax returns for 1990, 1991, 1992,
and 1994, petitioner reported tax liabilities which she paid when
she filed the returns.
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Last modified: May 25, 2011