- 4 -
On or about October 20, 2003, petitioner contacted the
Kansas City, Missouri, office and advised that she remained out
of work due to ongoing chemotherapy and was unable to pay her
outstanding tax liabilities. Representatives indicated that they
would send to petitioner a Form 433-A, Collection Information
Statement for Wage Earners and Self-Employed Individuals,3 and
asked that she call them back with the requested financial
information by November 10, 2003. On October 22, 2003, the
representatives tried to contact petitioner by telephone, but
when they were unsuccessful either in reaching her or in leaving
a message, they sent the previously discussed Form 433-A with a
letter asking that petitioner return the completed form by
November 5, 2003.
On October 29, 2003, petitioner provided financial
information telephonically to representatives of the Kansas City,
Missouri, office. After reviewing the information,
representatives determined that further substantiation was
needed. They again tried to reach petitioner by telephone or to
leave a message but were unsuccessful. At that juncture,
petitioner’s case was forwarded to the IRS Office of Appeals in
Jackson, Mississippi.
3 Respondent’s motion for summary judgment mistakenly refers
in several instances to a “Form 433-F”, rather than a “Form 433-
A”. The correct designation for the document is clear from the
record and is used throughout this opinion.
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