- 14 - $47,294 for 1986 and fully abated the assessed addition to tax under section 6661 for that year. The $9,453.66 abatement represented the tax attributable to the allowance of $20,222 in Schedule C deductions for 1986. This abatement, together with the $23,785.64 abatement made on May 27, 1996, described supra in D, resulted in a net assessed deficiency in income tax of $14,054.70 for 1986, as well as additions to tax under section 6653(a)(1)(A) and (B) for that year.10 Additionally on May 11, 1998, respondent issued petitioner a notice reflecting the above-described abatement of income tax and additions to tax for 1985, as well as an abatement of interest and late payment penalty. The notice also indicated that the amount to be refunded for 1985 was $17,866.18.11 Finally on May 11, 1998, respondent issued petitioner a notice reflecting the application of $6,166.80 of the $17,866.18 overpayment for 1985 to petitioner’s outstanding liability for 1986. One week later, on May 18, 1998, respondent issued petitioner another notice reflecting the application of $5,891.62 of the remaining overpayment for 1985 to petitioner’s outstanding liability for 1986. 10 The net assessed addition to tax under sec. 6653(a)(1)(A) was $703. 11 Petitioner had been making payments for a number of years against his assessed liability for 1985.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011