Larry G. Schuster - Page 3




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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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