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the tax collection waiver for 1979 on May 22, 1997. That waiver
reflected that she and Levy still had an unpaid tax liability for
1979 of more than $49,000.
Additionally, as respondent points out, petitioner’s Form
8857 states that she knew of the unpaid tax liabilities from
prior collection actions that respondent took against Levy’s
accounts. Although her Form 8857 does not specify the dates upon
which those collection actions against his accounts occurred,
respondent notes that such actions likely took place in March and
April of 1997. The Form 4340, Certificate of Assessments,
Payments, and other Specified Matters, for 1979 reflects that
respondent levied (1) $91.26 on March 7, 1997; (2) $113.98 on
April 10, 1997; and (3) $5,000 on April 10, 1997.
Petitioner, among other things, argues: (1) The Form 8857
(which petitioner signed) was prepared by her accountant, and (2)
the record does not definitively establish the dates the
collection actions referenced in the Form 8857 occurred.
Petitioner, however, overlooks the fact that her accountant
knew the details with respect to the collection actions
referenced in the Form 8857. Petitioner failed to offer her
accountant’s testimony. The accountant could have clarified that
these collection actions for 1979 involved levies upon Levy’s
accounts during March and April 1997.
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