- 3 -
nearly 4 years without his ever receiving a discharge. Mr.
Johnson's gross estate consisted of assets with a total fair
market value of $69,700.
At the time of his death, Mr. Johnson was liable for
outstanding assessed Federal income tax liabilities (excluding
interest) of the following amounts:
1979 1980 1981 1982 1983 1984 Total
Unpaid tax
liability $8,200 $4,604 $3,301 --- $6,849 $806 $23,760
Penalties:
� 6651(a)(1) 432 --- --- --- --- --- 432
� 6651(a)(2) 216 92 43 63 205 24 643
� 6654 360 294 330 310 420 145 1,859
Collection fees52 44 18 10 24 --- 148
Total 9,260 5,034 3,692 383 7,498 975 26,842
Federal tax liens for Mr. Johnson's 1979, 1980, 1981, 1982,
1983, and 1984 income tax liabilities arose when the taxes were
assessed on August 11, 1980, July 20, 1981, May 17, 1982, October
10, 1983, October 1, 1984, and September 16, 1985, respectively.
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