Brian and Tina Nicklaus - Page 3




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               On August 24, 1998, respondent made the following assess-              
          ments on Form 23C, Assessment Certificate--Summary Record of                
          Assessments (Form 23C),2 “per default of 90 day letter”, of                 
          petitioners’ tax liability for each of their taxable years 1993             
          and 1994 and sent a so-called notice of balance due to petition-            
          ers with respect to each of those years, and on August 31, 1998,            
          respondent made the following assessments on Form 23C, “per                 
          default of 90 day letter”, of petitioners’ tax liability for each           
          of their taxable years 1995 and 1996 and sent a notice of balance           
          due with respect to each of those years:                                    
                             1993        1994         1995        1996                
          Deficiency      $2,044.00  $2,516.00    $6,082.00    $9,352.90              
          Late filing     429.25     143.00       1,192.00     1,757.48               
          penalty                                                                     
          Accuracy-related408.80     263.20       --           --                     
          penalty                                                                     
          Estimated tax   –-         --           250.61       360.43                 
          penalty                                                                     
          Interest on     1,187.04   339.42       1,374.78     1,118.61               
          deficiency                                                                  
               At a time not disclosed by the record prior to November 25,            
          1998, petitioners received notice from respondent that respondent           
          intended to issue a notice of levy with respect to their taxable            
          years 1993 through 1995.  On November 25, 1998, respondent issued           
          a notice of levy with respect to those taxable years to each of             
          the following banks:  First Independent Bank in Vancouver,                  

               2The record does not contain Form 23C, Assessment                      
          Certificate--Summary Record of Assessments, that the Commissioner           
          of Internal Revenue uses to assess the tax liabilities of taxpay-           
          ers.  However, we have obtained and take judicial notice of that            
          form.                                                                       




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