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Background
On August 19, 1992, petitioner filed a Federal income tax
return for 1991 reporting a tax liability of $6,795. Respondent
subsequently entered assessments against petitioner for 1991
reflecting the tax reported due, additions to tax for failing to
pay estimated taxes and failing to pay the amount reported due,
and interest. Respondent applied overpayment credits from 1994,
1996, 1997, and 1998 to petitioner’s outstanding tax liability
for 1991. In addition, petitioner made a number of payments
against his tax liability for 1991 during the period 1993 to
1998.
On April 15, 1993, petitioner filed a Federal income tax
return for 1992 reporting a tax liability of $658.
On May 2, 1995, respondent issued a notice of deficiency to
petitioner determining a deficiency of $2,160 in his Federal
income tax for 1992. Petitioner did not file a petition for
redetermination with the Court challenging the notice of
deficiency.
On October 12, 1999, respondent mailed to petitioner a Final
Notice of Intent to Levy and Notice of Your Right to a Hearing
pursuant to section 6331.1 The notice stated that petitioner
owed taxes, penalties, and interest totaling $4,132.11 for the
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011