Connie A. Washington - Page 6

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               The Internal Revenue Service (IRS) issued to the Defense               
          Accounting Office a Notice of Levy on Wages, Salary, and Other              
          Income, Form 668-W(c) (the notice of levy), dated April 9, 1998,            
          and signed by Revenue Officer Barbara Whalen (Revenue Officer               
          Whalen), seeking to garnish petitioner’s wages.  The notice of levy         
          showed that petitioner and Mr. Washington were liable for unpaid            
          taxes and additions totaling $70,305.23, of which $809.01 of unpaid         
          tax and $4,557.27 of statutory additions related to 1989.  The              
          remaining amount was attributable to 1991 ($3,052.21), 1992                 
          ($32,255.95), 1993 ($25,578.40), and a civil penalty for 1988               
          ($4,052.39).  Mr. Washington’s name and address were typed below            
          “Name and Address of Taxpayer” on the notice of levy.  However, his         
          name and address were crossed out, and petitioner’s name and                
          address were inserted.                                                      
               On May 7, 1998, petitioner received a letter from the Defense          
          Finance and Accounting Service informing her that another notice of         
          levy had been issued on petitioner’s wages.  The letter stated that         
          her wages would be subject to garnishment until the $70,305 debt            
          was collected.  Petitioner was instructed to complete and return            
          parts 3 and 4 of the notice of levy.  She was informed that failure         
          to do so would result in her receiving a biweekly check in the              
          amount of $240.38 (the personal exemption amount), with the                 
          remainder (approximately $400) being forwarded to the IRS.                  








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