- 6 - liabilities of EMR for the fourth quarter of 1983, the first and fourth quarters of 1984, and the first and second quarters of 1985. This assessed amount equaled $42,407. Petitioner paid $18 with respect to the EPC liabilities and $88 with respect to the EMR liabilities, and he sued the United States on or about September 19, 1989, for a refund of these payments. The United States conceded that petitioner was not liable for the penalty with respect to EMR for the first and second quarters of 1985 and that the penalty with respect to EMR for the fourth quarter of 1984 was $4,927. In an order filed May 28, 1991, the District Court hearing the case ruled that petitioner also was not liable for the penalty with respect to EMR for the fourth quarter of 1983 and the first quarter of 1984. Thus, the total penalty against petitioner with respect to EMR was reduced to $4,927. On April 16, 1991, petitioner offered to settle the two refund cases for $31,000. One month later, the United States accepted his offer, and, in the next month, petitioner paid the United States $31,000 in complete satisfaction of his liability under section 6672. The United States applied petitioner's payment to the $107,006 penalty assessed against him with respect to the EPC liabilities. Petitioner had not designated any part of the payment as interest, and the United States did not apply any part of the payment to interest.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011