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worksheets showing that wages were withheld from petitioner’s pay
on December 24, 1997, and January 10, 1998, to satisfy the first
levy.
County technicians also prepared worksheets showing that
wages were withheld from petitioner’s pay on February 10 and 25,
and March 10, 1998, with reference to the second notice of levy.
Petitioner provided the Court with a copy of Form 668-D, Release
of Levy/Release of Property from Levy, that informed the County
that the levy on wages was being released as of the payment that
was withheld on March 10, 1998.
The County initially treated the notices of levy as
cumulative rather than treating the second notice as superseding
the first. The County worksheets show total net withholdings due
to the notices of levy of $4,658.23 (total withholdings of
$7,824.30 less “refunds” to petitioner of $1,685.29 on January 9,
1998, and $1,480.78 on March 10, 1998).
Respondent’s records show that he applied a total of
$4,658.23 in levy proceeds to petitioner’s tax liabilities for
1990, 1992, and 1993. Respondent’s records also show that
petitioner’s tax liabilities for 1990, 1992, and 1993 are fully
paid, and a zero balance is indicated for each year. According
to respondent’s records: (1) Levy proceeds of $314 were applied
to 1990 on January 21, 1998; (2) levy proceeds of $1,186, and
$733.89 were applied to 1992 on January 21 and March 20, 1998;
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