- 2 - 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.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011