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of $81,054.21, an addition to tax for 1966 due from petitioner
under section 6651(a) in the amount of $33,301.12, and an
addition to tax for the year 1966 in the amount of $6,660.22 due
from petitioner under section 6653(a). The additions to tax were
timely assessed on December 12, 1977.
Petitioner appealed our decision to the Court of Appeals for
the Ninth Circuit. The Court of Appeals affirmed our decision in
an unpublished opinion dated March 19, 1981.
During the first week of the calendar year 1988, the IRS
master file account for petitioner was credited $39,961 (the
total additions to tax determined by this Court for 1966) in an
entry coded "608". Code 608 means "statute expiration". The
entry was posted effective as of January 15, 1979. During the
fiftieth week of the calendar year 1989, the IRS master file
account for petitioner was debited $39,961 in an entry coded
"609". Code 609 means "reversal of statute expiration". This
entry was also posted effective as of January 15, 1979.
Petitioner did not receive the amounts owed to him by
respondent for 1966 within the time he had expected to receive
the refund. In October 1988 petitioner engaged an attorney to
expedite the issuance of the payment. On November 13, 1989,
respondent issued a check to petitioner in the amount of
$186,177.79. Respondent computed the amount of the payment made
to petitioner as follows:
Tax liability $76,439.88
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