Fay Dalton, Petitioner, and Robert Dalton, Intervenor - Page 3




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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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