William D. Colburn - Page 3
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1973, a $6 fee for collection costs (lien fee) was assessed on
petitioner's account for the taxable year 1966.
On September 18, 1973, petitioner made a payment to the
Internal Revenue Service (IRS) in the amount of $218,292.77 on
his 1966 tax liability to satisfy the Federal tax liens on land
he owned in Nevada. On October 15, 1973, respondent made a
refund to petitioner in the amount of $20,300.21, of which $49.93
was an interest overpayment.
In March 1971 respondent issued a notice of deficiency to
petitioner for the taxable year 1966 in which it was determined
that petitioner was liable for additions to tax pursuant to
sections 6651(a)(1) and 6653(a).1 Petitioner litigated his 1966
tax liability in this Court, docket No. 3625-71. On December 6,
1973, over the objection of respondent, petitioner was permitted
to amend his petition. Petitioner states that he amended his
petition to bring the issue of the 1966 tax liability into the
Tax Court proceeding.
An opinion was filed by this Court on February 3, 1977,
Colburn v. Commissioner, T.C. Memo. 1977-29, and pursuant to the
opinion a decision was entered under Rule 155 on July 22, 1977.
In accordance with the opinion, the decision set forth an
overpayment of tax due petitioner for the year 1966 in the amount
1 All section references are to the Internal Revenue Code in effect for
the year in issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure, unless otherwise indicated.
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