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Background
A. Substitute For Returns and Petitioners’ First Amended
Returns
Petitioners failed to file timely Federal income tax returns
for 1992, 1993, and 1994. On January 23, 1995, respondent
prepared a substitute for return with respect to petitioners’
taxable year 1992. See sec. 6020(b). On August 30, 1995,
respondent prepared substitutes for return with respect to
petitioners’ taxable years 1993 and 1994. Id.
On October 2, November 3, and December 11, 1995, petitioners
submitted and respondent accepted late-filed original tax returns
for the taxable years 1992, 1993, and 1994, respectively. Each
of the above-referenced returns showed taxes due. On February
12, 1996, respondent assessed the taxes shown as due on those
returns, plus late filing penalties, and estimated tax penalties
as follows:
Additions to Tax
Year Income Tax Sec. 6651(a)(1) Sec. 6654
1992 $4,978 $1,245 $217
1993 2,521 335 50
1994 4,194 1,049 218
On February 12, 1996, respondent also assessed statutory interest
in the amounts of $1,612.91, $291.73, and $418.28 for the taxable
years 1992, 1993, and 1994, respectively. On February 12, 1996,
respondent sent petitioners notices of balance due, informing
petitioners that they had tax liabilities for 1992, 1993, and
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Last modified: May 25, 2011