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On December 23, 1996, respondent sent petitioner a notice of
deficiency which was substantively identical to the examination
report. Petitioner did not timely file a petition with this
Court. See sec. 6213(a). Rather, petitioner paid the
deficiency in tax, but not the interest thereon. Thus, on March
27, 1997, a payment of $9,698 was posted to petitioner’s account.
On May 26, 1997, respondent assessed the $9,698 deficiency
in income tax, together with interest of $802.12. See secs.
6213(a), 6503(a)(1). On that same date, respondent also sent
petitioner a notice of balance due regarding the unpaid interest.
2. Payment of Petitioner’s Account Balance
As of May 26, 1997, petitioner’s account balance was
$802.12, calculated as follows:
Date Event Amount
Mar. 27, 1997 Advance payment ($9,698.00)
May 26, 1997 Assessment/tax 9,698.00
May 26, 1997 Assessment/interest 802.12
802.12
By April 15, 2000, petitioner’s account was fully paid
through: (1) A levy on a Georgia State income tax refund that
was due petitioner; and (2) the application of part of an
overpayment of income tax claimed by petitioner on her 1999
Federal income tax return. See sec. 6402(a).
3. Petitioner’s Claim for Abatement of Interest
Using Form 843, petitioner filed with respondent on or about
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