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$168.02 to the unpaid liability stemming from taxable year 1994.
The OIC Case history shows that while respondent’s collections
personnel did not contact petitioners about petitioners’ unpaid
liability for taxable year 1994 until early 2001, the collections
personnel were in contact with petitioners between 1997 and 2001
regarding their unpaid tax liabilities stemming from taxable
years 1997, 1998, and 1999.
Regarding the outstanding assessment for 1994, respondent
attempted to contact petitioners by telephone no less than 10
separate times between 2001 and 2004. Respondent also sent
petitioners three letters; in two of these letters, he warned
petitioners of default, and in the third, he notified petitioners
of default.
The OIC Case history Listing is replete with notations that
respondent’s Collections employees and managers reviewed
petitioners’ record for taxable year 1994 for payments, received
approval to proceed with collections, and attempted contact with
petitioners when no payments were received. Accordingly, we
conclude that the review undertaken by respondent’s employees in
this case was as thorough and complete as possible given
petitioners’ noncompliance with the 5-year timely filing and
paying requirement imposed by the OIC, and the inability of
respondent’s employees to contact petitioners.
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Last modified: May 25, 2011