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penalty under section 6662(a) in the amount of $11,451. At the
time the notice of lien involved in this case was filed, some
part of the deficiency for 1993 had not been paid.
Petitioner’s 1995 Federal Tax Return
Petitioner obtained an extension to August 15, 1996, to file
his 1995 Federal income tax return. On February 17, 1997,
respondent sent to petitioner a delinquency notice requesting
that he file his 1995 return. The Internal Revenue Service (IRS)
received an unsigned and undated 1995 return for petitioner on
March 31, 1997; the return gave an address for petitioner in
Woodside, California.
Shortly thereafter, the IRS made a mathematical adjustment
to the 1995 income tax return relating to whether petitioner
should receive credit for $3,800 in estimated tax payments or tax
payments from a prior year against his tax liability of
$3,857.41. The IRS sent to petitioner a notice of balance due.
On July 25, 1997, the IRS filed a Notice of Federal Tax Lien for
1995 and for taxes outstanding for other periods. In July 1998,
a payment of $6,748.62 was applied to the 1995 liability. This
amount included tax of $3,857.41, an estimated tax penalty of
$210.58, a late filing penalty of $867.92, a failure to pay tax
penalty of $771.48, and assessed interest totaling $1,041.23.
After the payment, the IRS abated $250.73 of the previously
assessed failure to pay tax penalty and the entire $867.92 late
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