Annette D. Goode-Parker - Page 5

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          “purple pencil people.”2  It was one of these people who caught             
          and corrected the Parkers’ mistake.  The Commissioner then                  
          assessed the correct amount of tax--$28,446--in the IRS’s                   
          records.  Because there was a balance due, the Commissioner began           
          trying to collect, unencumbered by the Code’s current due process           
          requirements.3  First, he filed a Federal tax lien on the                   
          Parkers’ condominium in March 1998.  Then, in November 1998, he             
          levied on Ms. Goode-Parker’s bank account.  We specifically find            
          that she is credible in saying that this was the first she knew             
          of her and her husband’s tax trouble.  She promptly contacted the           
          IRS, and for the next three years made monthly payments of $50.             
               In September 2000, the strains on the Parkers’ marriage                
          became very great:  They still resided in the same condo, but               
          began living separate lives and keeping to different rooms.  In             
          February 2002, Ms. Goode-Parker filed a Form 8857, requesting               
          innocent spouse relief from the Parkers’ joint 1996 tax                     
          liability.  In November 2002, before the Commissioner made his              
          determination, the Parkers separated in the traditional sense.              

               2 An IRS supervisor, though not himself a purple pencil                
          person, credibly testified that as part of his duties he                    
          proofreads returns processed by the purple pencil people, and               
          that the purpose of purple pencil people is to point out patent             
          problems on returns with a purple pencil.                                   
               3 The collection due process requirements in sections 6320             
          and 6330 became effective for collection actions begun on or                
          after January 19, 1999.  Internal Revenue Service Restructuring             
          and Reform Act of 1998, Pub. L. 105-206, sec. 3401(d), 112 Stat.            

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