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a followup letter dated October 20, 2004, enclosing a Form 433-A,
noting that a $700 monthly installment payment did not appear
unreasonable based on the financial information provided to date,
and encouraging petitioner to provide information that she felt
accurately described her current financial situation and a
specific alternative to the proposed $700 monthly payment.
On October 21, 2004, respondent filed a motion for summary
judgment. The Court issued an order directing petitioner to file
any response on or before December 3, 2004, and in the interim,
on November 22, 2004, held a conference call with the parties to
encourage them to work together in resolving this matter and to
impress upon petitioner the importance of current and accurate
financial data. On December 2, 2004, a letter received from
petitioner was filed as her response to the motion for summary
judgment. In that document petitioner stated, inter alia:
I take full responsibility for not paying taxes in the
90s and for not having enough withheld in the early
2000s. Prior to this time, I always paid my tax
obligations. I thought it would be easy for me to play
‘catch up’ and pay the taxes at a later date, but I
didn’t factor in the penalties and interest the IRS
would add to the tax bill. I did have a payment plan
with the IRS and was making payments until I was
diagnosed with a brain tumor and underwent brain
surgery. Right now, I’m in the biggest fight of my
life-the fight for my life-and I must be honest with
you, my tax obligation has not been a priority. I know
I’m still responsible for this liability and I am
willing to resolve this matter, but I cannot afford
$700 per month.
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Last modified: May 25, 2011