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were turned over to the IRS as a result of these levies. At
trial, respondent produced IRS transcripts that reflected the
following amounts realized from these levies:
For the 1986 tax year:
$ 661.05 Sept. 28, 1992
918.29 Sept. 14, 1993
3,084.23 Sept. 17, 1993
54,532.26 July 17, 1991
$59,195.83 Total levies for 1986 tax year
For the 1987 tax year:
$3,823.00 Sept. 17, 1993
The Federal income tax returns of petitioner for 1986 and
1987, respectively, were received and filed by the IRS on
April 16, 1992, and March 4, 1992. Petitioner did not report
either the capital gain realized on the stock sales during 1986
nor any of the interest and dividends received on the stock, bank
accounts, and certificates of deposit that were jointly in her
and Sandra's names. However, sometime after filing her 1986 and
1987 returns (and presumably feeling the sting of the sizeable
levies by respondent), petitioner came forward and made known to
the IRS that she and not Sandra owned the stock sold during 1986,
and that petitioner also owned all of the various bank accounts
and certificates of deposit that were titled jointly with Sandra.
In the resulting audit of petitioner's 1986 and 1987 tax years,
respondent determined the gain realized from the stock sales and
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