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petitioner's 1988 taxable year. Also on September 2, 1991, the
Service issued to petitioner the first notice of balance due for
his 1988 taxable year in the amount of $2,187.83. On October 7,
and November 11, 1991, the Center sent petitioner additional
notices of balance due for his 1988 taxable year, both showing
$2,187.83 due. On December 16, 1991, the Center sent petitioner
a notice of intent to levy for his 1988 taxable year.
During early 1992, Revenue Officer Bonnie MacKay informed
petitioner that he needed to file returns for 1987 and 1988
within 30 days and that she would send to him the necessary
records and information as soon as possible. One of the records
that Ms. MacKay sent petitioner was a copy of the ASFR Account
Transcript for 1987, dated April 26, 1991. On December 11, 1996,
the Service served a levy in the amount of $1,745.88 on
petitioners’ joint bank account. The levy was released on
December 16, 1996.
After December 17, 1996, petitioner mailed returns to the
Service for his 1987 and 1988 taxable years because the tax liens
arising from the unpaid assessments for those years prevented him
from qualifying for a mortgage. The Center received petitioner's
returns on January 9, 1997. A letter from petitioner's
accountant, David M. Wojeski, dated October 24, 1996, pointing
out the error in the wage income that petitioner received from
the school for 1987 ($351 instead of $35,100), was attached to
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