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and Mr. Collier reported total tax of $10,539 and tax due of
$5,521. Ms. Collier and Mr. Collier did not pay any tax at the
time they filed the 1990 joint return.
On May 20, 1991, respondent assessed $10,539 with respect to
the taxable year 1990 of Ms. Collier and Mr. Collier. Respondent
applied $5,018 of tax withheld against that assessment, which
left $5,521 unpaid. In November 1997, Mr. Collier entered into
an installment agreement (1997 installment agreement) with
respect to the unpaid assessment for 1990.5
Ms. Collier and Mr. Collier jointly filed Form 1040 for 1991
(1991 joint return). Mr. Collier signed that return. A signa-
ture for “Sandrus Collier” appeared under the signature of Mr.
Collier in the 1991 joint return. Ms. Collier intended to file
that return jointly with Mr. Collier and did not file a separate
return for 1991. In the 1991 joint return, Ms. Collier and Mr.
Collier reported total tax of $12,778 and tax due of $8,528.6 At
the time Ms. Collier and Mr. Collier filed the 1991 joint return,
Ms. Collier did not believe that payment was made of the $8,528
of tax due shown in that return, and they did not pay any tax at
5The record does not disclose whether Mr. Collier made any
payments under the 1997 installment agreement.
6There was a mathematical error in the computation of the
amount of tax due shown in the 1991 joint return. That return
reported total tax of $12,778 and total payments of $4,628. The
1991 joint return incorrectly reported the amount of tax due as
$8,528. The difference between $12,778 and $4,628 is $8,150.
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Last modified: May 25, 2011