John Douponce - Page 3




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          $995 was applied to his account for 1988.  On March 18, 1996, a             
          credit (from petitioner's 1995 taxable year) of $809 was                    
          similarly applied to 1988.  When the March 18, 1996, payment was            
          applied, petitioner's entire liability for tax and penalties for            
          1988 was extinguished.  The sum of $252.63, the balance after               
          satisfying the tax and penalty liability, was applied to interest           
          that had accrued for 1988.  In March 1996, petitioner submitted             
          an Offer in Compromise with respect to the balances owed for                
          1988, 1990, and 1991.  On May 9, 1996, after additional exchanges           
          of correspondence between petitioner and respondent, petitioner's           
          Offer in Compromise was rejected on the ground that there was no            
          doubt as to liability.  Also on or about May 9, 1996, petitioner            
          telephoned respondent's Glendale, California, office to ascertain           
          the balance then outstanding on his accounts for 1988, 1990, and            
          1991.  An employee of respondent told petitioner that the                   
          following amounts had been assessed and remained outstanding:               
          1988--nothing; 1990--$2,196; and for 1991--$2,492.  Respondent’s            
          employee also told petitioner to add $100 to each of these                  
          amounts.  Petitioner understood these amounts to be the full                
          amounts of his liabilities for these years, including all tax               
          due, penalties and interest.  On May 30, 1996, petitioner paid              
          respondent the amounts of $2,296 for 1990 and $2,592 for 1991.              
          These payments were credited to petitioner’s 1990 and 1991                  
          accounts on May 30, 1996.  On June 24, 1996, respondent assessed            






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