- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011