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petitioner’s outstanding tax liability for 1994 consisted of $536
of tax and $600.27 of interest.
On June 12, 1997, respondent levied on petitioner’s bank
account located at the First Interstate Bank-Commerce in
Billings, Montana, for the amounts petitioner owed for the years
1992, 1993, and 1995. On July 10, 1997, respondent received
$1,631.48 from First Interstate Bank-Commerce and credited the
full amount to petitioner’s 1992, 1993, and 1994 tax liabilities.
As a result, petitioner’s 1993 tax liability was fully paid.4
On July 20, 1997, respondent issued a second levy, this time
on petitioner’s bank account located at the State Capitol
Employees Credit Union in Helena, Montana. The notice of levy
stated that the levy was for unpaid tax liabilities for 1993 and
1995 in the amounts of $1,134.57 and $129.34, respectively, for a
total of $1,263.91. On August 14, 1997, respondent received
$1,263.91 from the State Capitol Employees Credit Union. Because
petitioner’s 1993 tax liability had already been satisfied by the
June 12, 1997, levy, the $1,263.91 was shown as an overpayment on
petitioner’s 1993 account. Respondent then applied the proceeds
of the July 20, 1997, levy to petitioner’s 1994, 1995, and 1996
unpaid tax liabilities in the amounts of $1,014.03, $129.40, and
4The levy proceeds were credited to petitioner’s accounts as
of July 10, 1997.
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