- 3 - be $11,767, as indicated by a calculator tape attached to her return. The $16,204 reported as “wages, salaries, tips, etc.” on petitioner’s 1990 return is the sum of the wages reported on the Forms W-2 listed above, plus petitioner’s estimate of her earnings from the law firm. Taking into account unchallenged deductions, her 1990 return lists her Federal income tax liability as $1,639. Federal income tax withholdings of $449 are applied against this liability resulting in a Federal income tax of $1,190 to be paid with her return. No income tax payment, however, was submitted with petitioner’s return. Statements contained in a letter attached to petitioner’s 1990 return suggest that petitioner might have been experiencing financial difficulties at the time her 1990 return was filed. On May 20, 1991, respondent assessed the income tax liability of $1,639 reported on petitioner’s 1990 return, plus a late payment penalty of $11.90, and interest of $11.47. The late payment penalty and interest take into account the Federal income tax withholdings reported on petitioner’s return. As it turned out, petitioner underestimated and underreported her 1990 earnings from the law firm. On November 27, 1992, respondent, reacting to information received from the law firm, sent petitioner a notice of proposed changes to her 1990 return. In that notice, respondent proposed to increasePage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011