- 3 - 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 latePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011