-7-
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011