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or Levy Action under Code Section 6320(c) or 6330(d) which
stated:
I have eleven children aged 47 to 21. Six have
college degrees; two are close to degree completion.
All are taxpaying citizens and student loan paying
citizens in some cases. My indirect contribution to
tax coffers is large and ongoing.
* * * * * * *
Most of our funds help our children who with student
loans and in spite of work need help with emergencies
and medical matters, etc. These aren’t allowable with
you, but they are real. This month one my [sic]
paychecks paid for my youngest daughter’s deductible
car insurance in order for her to obtain her car back
from repairs after an accident (not her fault) and her
car insurance. She has a child, goes to college, work
and daycare. You may not call this a necessity I do
[sic].
* * * * * * *
My petition for relief is simple. Declare this
account uncollectible.
The amended petition also stated that the “levy or enforcement of
lien would be punitive and destructive to taxpaying citizens and
their family at a loss not a gain to the Federal Government”.
Prior to the issuance of this opinion, the Court held a
conference call with the parties to determine whether a
settlement could be reached. It became apparent to the Court
that settlement could not be reached.
Discussion
Petitioners do not dispute that the amount of taxes owed,
additions to tax, penalties, and statutory interest assessed are
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Last modified: May 25, 2011