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$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.
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