- -3 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011