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to taxable years 1992 and 1995 of petitioner and Mr. Armstrong,3
respondent assessed on the dates shown the following amounts of
tax, an addition to tax, and interest:
Date of Addition Total
Year Assessment Tax to Tax Interest Liability
1992 2/22/1999 $8,604.00 --- $4,808.21 $13,412.21
1995 11/25/1996 300,609.00 $9,758.24 13,278.23 1323,659.47
1Form 4340 for taxable year 1995 of petitioner and Mr.
Armstrong also reflects a $14 charge for “FEES AND COLLECTION
COSTS”, making the total liability for that year $323,659.47.
As reflected in Form 4340 with respect to petitioner’s
taxable year 1992, respondent credited $1,000 of tax withheld to
the account of petitioner and Mr. Armstrong for their taxable
year 1992, thereby reducing their unpaid liability for that year
to $12,412.21.
As reflected in Form 4340 with respect to petitioner’s
taxable year 1995, respondent credited $6,653 of tax withheld, an
estimated tax payment of $50,000, and a payment of $49,995.94 to
the account of petitioner and Mr. Armstrong for their taxable
year 1995, thereby reducing their unpaid liability for that year
to $217,010.53.
On August 8, 2000, respondent issued to petitioner a final
notice of intent to levy (notice of intent to levy) with respect
3For convenience, we shall hereinafter refer to respective
Forms 4340 with respect to taxable years 1992 and 1995 of peti-
tioner and Mr. Armstrong as respective Forms 4340 with respect to
petitioner’s taxable years 1992 and 1995.
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Last modified: May 25, 2011