William Reese - Page 7

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                         Income tax     IRC Sec. 6651(a)    IRC Sec.                  
               Year      deficiency     addition to tax     6654                      
               1992      $20,106        $4,953              $613                      
               Petitioner had a withholding credit in the amount of $295 to           
          be credited toward the deficiency due for calendar year 1992.               
                                     Discussion                                       
               In light of petitioner’s “request for relief and statement             
          of error” in his petition, referred to above, in which he                   
          requested “abatement of all excessive and wrongful IRS                      
          assessments,” and “Proper accounting of my liability,” the Court            
          issued an Order requiring respondent to supplement his Motion in            
          certain respects.  The Order required the following:                        
                    ORDERED that on or before November 18, 2005,                      
               respondent shall supplement his [summary judgment]                     
               motion with a statement showing petitioner’s current                   
               outstanding Federal income tax liabilities for the                     
               years 1988, 1989, 1990, 1991, and 1992.  It is further                 
                    ORDERED that the statement described in the                       
               foregoing paragraph shall:  (1) Explain how the                        
               liability for each year has been computed; (2) explain                 
               why amounts listed in the “Paying Late Penalty” column                 
               (presumably the addition to tax imposed by I.R.C.                      
               section 6651(a)(3))[2] in respondent’s final notice of                 
               intent to levy, dated March 22, 2004, are not reflected                
               in the transcripts of account attached to respondent’s                 
               motion; and (3) demonstrate the allowance of Federal                   
               income tax withholdings for 1989, 1990, and 1992 which                 
               are not taken into account in respondent’s final notice                
               of intent to levy, dated March 22, 2004.  It is further                



               2This is not expressly stated in the Levy Notice or the                
          Notice of Determination.                                                    





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