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tax, interest, and fees. On August 31, 1999, those amounts were
as follows:
Unpaid Unpaid Additions to Tax and Interest
Year Income Tax Sec. 6651(a)(1) Sec. 6651(a)(2) Interest
1985 $2,308.83 $1,153.80 $1,282.00 $14,998.10
1986 1,765.00 419.63 466.25 4,905.82
1987 1,019.00 229.28 254.75 2,334.63
1992 155.61 453.60 343.04 1,094.82
1994 1,714.00 385.65 428.50 997.72
1995 2,005.00 --- 501.25 664.67
Total 8,967.44 2,641.96 3,275.79 24,995.76
Respondent also assessed $18 for a lien fee for 1992.
We must decide the following issues:
1. Whether petitioner is entitled to relief under section
6320. We hold that he is not.
2. Whether petitioner is liable for the amounts determined
by respondent (including additions to tax and interest) for the
years 1985, 1986, 1987, 1992, 1994, and 1995. We hold that he
is.
3. Whether respondent may proceed with levy action. We
hold that respondent may.
Section references are to the Internal Revenue Code. Rule
references are to the Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011