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B. Petitioner's Returns for 1985-91
On July 21, 1992, petitioner read an article in the Rocky
Mountain News which said that respondent had designed a program
to encourage nonfilers to file late returns without being subject
to criminal penalties. The program required nonfilers to pay
back taxes and penalties. The program offered a payment plan for
payment of taxes and penalties. The article did not mention
interest payments. On October 27, 1992, in response to the
article, petitioner filed Federal income tax returns for 1985 to
1991.
Petitioner reported on his 1985 return that he owed $3,199
in tax and that he had not paid any of that amount. He did not
make any payment with his 1985 return.
C. Respondent's Notices in 1993
On April 12, 1993, respondent sent petitioner a notice
stating that petitioner owed tax of $3,416.31 and a penalty of
$854.08 for filing late, for a total of $4,270.39. The notice
said:
We changed your 1985 return because: an error was
made on your return when the amount of your social
security self employment was transferred from Schedule
SE (Form 1040).
As a result of these changes, you owe $4,270.39.
Please pay the amount you owe by April 22, 1993, to
avoid more interest and penalties. * * *
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