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Amount
Pension income $10,686
Unemployment compensation 4,280
Barter income 472
State income tax refund 188
Total $15,626
During 1995, petitioner knew that intervenor received the
above pension income, unemployment compensation, and State income
tax refund, and petitioner was aware that intervenor and Itex,
the company from which intervenor received the barter income, had
some relationship.
On April 23, 1997, respondent issued to petitioner and
intervenor the notice of deficiency for 1995 reflecting the above
additional items of income and the tax deficiency of $4,123.
Neither petitioner nor intervenor petitioned this Court for a
redetermination of the deficiency.
On September 22, 1997, respondent assessed the $4,123
deficiency against petitioner and intervenor. Subsequently,
respondent assessed $407 in interest and penalties against
petitioner and intervenor.
In collection of the above total $4,530 in tax, interest,
and penalties that had been assessed against petitioner and
intervenor, respondent applied a credit of $2,137 for funds that
had been withheld by respondent from intervenor’s 1995 pension
income. Also, respondent withheld from intervenor income tax
refunds due intervenor for 1996 and 1997 in the amounts of $411
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Last modified: May 25, 2011