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payment resulted, quite simply, from petitioner’s failure to pay
the 1988 liability that she and Frank reported on their 1988
joint return or else to ensure that Frank was taking care of it.
The evidence does not suggest that petitioner’s failure to pay
the 1988 liability resulted from respondent’s classifying it as
uncollectible. Indeed, the evidence does not indicate when
petitioner might have first become aware that respondent had
classified the 1988 liability as uncollectible.
On brief, petitioner acknowledges that “there is no question
that Petitioner was aware of the [1988] tax liability at the time
the return was filed”. Similarly, petitioner acknowledges that
she “knew at the time she left her husband there was an
outstanding liability”. She states on brief that she “did not
lack the ability to pay the liability after she left her husband
in February, 1990”. Nevertheless, she claims that no significant
aspect of the delay in payment was attributable to her, because
respondent failed to send her additional notices of the balance
due. Although intrigued by the novelty of a complaint that the
IRS has failed to hound the taxpayer enough, we find therein no
basis to grant petitioner relief.
In July 1989, respondent sent petitioner and Frank a
notification of the 1988 liability they had reported on their
joint return. Respondent was under no obligation to send
additional notices. Whether respondent acted improvidently in
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