- 15 - 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 andPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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