- 4 -
Total tax $62,602
Less: estimated tax payments
Sept. 1993 $30,000
Jan. 1994 2,360 -32,360
Less: deferral of additional
1993 taxes1 -1,963
Balance 28,279
Plus: estimated tax penalty 111
Amount owed 28,390
1For 1993, taxpayers could elect to defer two-thirds of
their additional 1993 taxes that were due solely to the rate
increases reflected in the 1993 tax rate schedules. Omnibus
Budget Reconciliation Act of 1993, Pub. L. 103-66, sec. 13201(d),
107 Stat. 459-461. Petitioners so elected by attaching Form
8841, Deferral of Additional 1993 Taxes, to their timely filed
return.
Petitioners remitted $500 with their 1993 return, but they
made no further payment against their tax liability until August
1997. See infra “E”.
By notice dated June 13, 1994, respondent notified
petitioners that they did not qualify for deferral of additional
1993 taxes because they had failed to make sufficient payment
toward their reported liability.3 Respondent also notified
petitioners that the amount owed was $31,602, determined as
follows:
Tax as reported $62,602.00
Less: Estimated tax payments -32,360.00
Payment with return -500.00
Unpaid tax 29,742.00
Plus: estimated tax penalty 1,224.45
Late payment penalty 297.42
Interest 338.41
Amount owed 31,602.28
Finally, respondent requested that petitioners pay the amount
3 In order to qualify for deferral of additional 1993
taxes, a taxpayer was required to pay at least 90 percent of a
specified liability. See Notice 93-51, 1993-2 C.B. 337.
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Last modified: May 25, 2011