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1040 for the taxable year 1995 (1995 Form 1040). At the time
petitioner signed that form, she was aware that the bankruptcy
judgments had been entered against Mr. Butner and herself and had
not been satisfied. On March 10, 1999, petitioner and Mr. Butner
filed late their 1995 Form 1040. In that form, petitioner and
Mr. Butner reported self-employment tax owed of $10,198 and a
total amount owed of $10,198.
On May 24, 1999, an assessment of self-employment tax of
$10,198 was made for the taxable year 1995. On the same date,
interest of $3,682.21 and penalties of $4,788.90 were also
assessed for that year. As of May 24, 1999, the total unpaid
assessed liability for the taxable year 1995 was $18,669.11. At
the time in June 2003 the Appeals officer considered petitioner’s
request for relief under section 6015, the total unpaid assessed
liability for that year was the same amount, excluding any
addition to tax and interest accrued after May 24, 1999.
On August 25, 2000, petitioner and Mr. Butner filed Form
1040X for the taxable year 1995 (1995 Form 1040X). In that form,
petitioner and Mr. Butner reported no self-employment tax due and
no tax liability. Respondent did not accept as correct the 1995
Form 1040X of petitioner and Mr. Butner.
On October 25, 1999, notices of Federal tax lien were filed
against petitioner and Mr. Butner with respect to their respec-
tive liabilities for the taxable years 1994 and 1995.
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Last modified: November 10, 2007