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to the 1988 liability. In neither instance did the notification
state the outstanding balance of the 1988 liability.5
On her 1994 return, petitioner reported taxable wages of
$50,560. On the basis of this information, on May 29, 1995,
respondent determined that the 1988 liability should no longer be
classified as uncollectible. On August 7, 1995, respondent
assigned petitioner’s case to revenue officer Garrie Ollie
(Ollie) for collection action.
On April 5, 1996, Ollie issued to petitioner’s employer in
Salinas, California, a notice of levy on petitioner’s wages with
respect to the 1988 liability. The notice shows an unpaid
balance on the 1988 liability of $16,292, plus statutory
additions (late-payment penalties and interest) of $19,391, for a
total amount due of $35,683. Petitioner then contacted Ollie and
entered into an installment agreement to pay the 1988 liability.
In June 1996, petitioner began making monthly payments. On
January 22, 1997, petitioner made a lump-sum payment of $12,939
in satisfaction of the remaining balance on the 1988 liability.
5 The text within each notification describes the 1988
liability as being “under” Frank’s Social Security number. Each
notification, however, shows petitioner’s taxpayer identification
number (i.e., her Social Security number) at the top and bears
the caption “OVERPAID TAX APPLIED TO OTHER FEDERAL TAXES OWED ON
SECONDARY SOCIAL SECURITY NUMBER” (i.e., on petitioner’s Social
Security number).
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Last modified: May 25, 2011