- 21 -
boxes. Respondent seized property from Larry’s home on June 15,
1994, and from Katherine’s home on June 17, 1994. Larry and
Nancy filed an administrative protest on July 15, 1994, in which
they requested abatement of the jeopardy assessment. Respondent
abated the jeopardy assessment on or about November 18, 1994, but
imposed an equitable lien on Larry’s real property.
On August 12, 1994, respondent mailed a notice of deficiency
to Larry and Nancy for the years 1983 through 1990. Respondent
determined the deficiencies set forth in that notice of
deficiency on the basis of a source and application of funds
analysis for each of those years. On November 14, 1994, Larry
and Nancy filed a petition with the Tax Court seeking a
redetermination of those deficiencies (docket No. 20854-94).
Respondent, Larry, and Nancy subsequently settled docket No.
20854-94. The decision document, entered February 20, 1996,
reflected, among other things, that (1) no deficiencies in tax
were due for the years 1983 through 1988, (2) no additions to tax
were due for the years 1983 through 1988, (3) deficiencies in tax
were due for years 1989 and 1990 in the amounts of $7,140 and
$6,606, respectively,12 (4) additions to tax were due for years
12 In the notice of deficiency, respondent determined tax
deficiencies for 1989 and 1990 of $13,317 and $16,461,
respectively. Those deficiencies were calculated on the basis of
the following adjustments to income:
(continued...)
Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 NextLast modified: May 25, 2011