- 2 -
COHEN, Judge: Respondent sent to petitioner a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 with respect to petitioner’s Federal income taxes for
1992 and 1996. Petitioner contests the levy on the ground that
the amounts in issue were paid by excess taxes withheld in
earlier years. Respondent declined to apply the excess
withholding from years for which returns were filed more than
3 years late. Unless otherwise indicated, all section references
are to the Internal Revenue Code in effect for the years in
issue.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated by this reference. Petitioner resided in
Spring, Texas, at the time that he filed his petition. Prior to
and during the years in issue, petitioner was employed as a staff
financial representative for Royal Dutch Shell Group. He is
educated as an accountant and prepared and filed his own tax
returns.
For all years from 1989 through 1998, petitioner filed joint
tax returns with his wife, Deborah B. Landry. Petitioner’s 1989
return was filed on April 15, 1993. His returns for 1990, 1991,
and 1992 were filed on or about April 15, 1997. His returns for
1993, 1994, 1995, and 1996 were filed no earlier than June 1997.
Petitioner’s return for 1997 was filed in April 1999.
Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011