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petitioners' tax returns for 1995 and 1996, respectively, to
partially offset the assessment made against petitioners for
1990. After making an additional assessment against petitioners
in the amount of $14 for collection costs, the assessment made
against petitioners for 1990 totaled $105,412.65.
On September 10, 1997, respondent issued to petitioners a
final notice of intent to levy listing $207,743.97 as the amount
purportedly due from petitioners for the 1990 taxable year. The
$207,743.97 amount is identified as $112,065.34 (assessed amount
unpaid from prior notices) and $95,678.63 (additional penalty and
interest).
On October 9, 1997, respondent issued a notice of deficiency
to petitioners determining a deficiency in their Federal income
tax for 1990 in the amount of $321,079, and an accuracy-related
penalty pursuant to section 6662(a) in the amount of $64,216.
The notice of deficiency is based on the proposed adjustments
that were outlined in respondent's 30-day letter described above.
Also on October 9, 1997, respondent issued a notice of
deficiency to petitioners determining deficiencies in and
additions to their Federal income taxes for 1991, 1992, and 1993.
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