Willie Nelson Hopes for a Hit; So Does the I.R.S.

Since Willie Nelson's "Who'll Buy My Memories? (The I.R.S. Tapes)" went on sale in June, it has sold only 160,000 copies. Under Mr. Nelson's unusual arrangement with the Government, the collection of 25 songs must sell at least four million copies if it is to erase the singer-songwriter's tax obligations.

"You got to be positive," Mr. Nelson said in an telephone interview last week. "It's not unheard of. I could sell three million albums. I've done it before." He hopes sales will improve when the collection is available in stores; it is sold now only through phone orders advertised mostly on late-night television.

When Mr. Nelson was served last year with a $32 million bill for delinquent taxes -- one of the largest ever presented to an individual -- it seemed unlikely that anyone, even the cowboy heroes of his country and western songs, could rescue him.

But after months of negotiation with the Internal Revenue Service, Mr. Nelson made a deal that allowed him to bring out the collection -- yours, for a limited time only, in cassette or compact disk, for $19.95 (plus $4 for shipping and handling), by dialing (800) IRS-TAPE.

The collection includes 25 examples of Mr. Nelson's Texas twang and acoustic guitar. [ Review, page 26. ] The plan is to apply at least 15 cents from every $1 of sales to the musician's back taxes.

Laurence Goldfein, Mr. Nelson's business manager, said $9.95 of every $19.95 goes to the telemarketing company that is doing the distribution and marketing; about $2.40 goes to the Sony Corporation, Mr. Nelson's record company, and $1.60 to other expenses.