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for petitioner’s taxable year 1987: Tax of $1,492; additions to
tax under section 6651(a)(1) for failure to file timely and
section 6651(a)(2) for failure to pay timely of $119.48 and
$71.68, respectively; and interest of $176, all of which respon-
dent reflected in Form 4340, CERTIFICATE OF ASSESSMENTS, PAY-
MENTS, AND OTHER SPECIFIED MATTERS (Form 4340). On June 18,
1990, respondent sent petitioner a delinquency notice with
respect to her unpaid liability for 1987 of $531 in tax and
$191.16 in additions to tax, plus interest as provided by law on
those amounts.2 (For convenience, we shall refer to petitioner’s
liability for unpaid tax, unpaid additions to tax, and interest
as provided by law on such unpaid tax and such additions to tax
as petitioner’s unpaid liability.) As of the date of trial in
this case, petitioner had not paid any portion of petitioner’s
unpaid liability for 1987.
Petitioner filed a return for her taxable year 1988 on May
18, 1990. In that return, petitioner showed $1,676 as tax for
1988. As of April 15, 1989, petitioner had a withholding credit
of $186 with respect to that tax. On June 18, 1990, respondent
timely assessed the following for petitioner’s taxable year 1988:
Tax of $1,676; additions to tax under section 6651(a)(1) for
failure to file timely and section 6651(a)(2) for failure to pay
2Respondent had previously sent petitioner delinquency
notices with respect to her taxable year 1987 on July 31, 1989,
Sept. 25, 1989, Feb. 5, 1990, and Mar. 19, 1990.
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