Billye S. Cannon - Page 3




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          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 increase               






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