Simone Joye - Page 4




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          timely of $335.25 and $111.75, respectively; and interest of                
          $261.45, all of which respondent reflected in Form 4340.  On June           
          18 and July 23, 1990, respondent sent petitioner a notice of                
          balance due with respect to her unpaid liability for 1988 of                
          $1,490 in tax and $447 in additions to tax, plus interest as                
          provided by law on those amounts.  As of the date of trial in               
          this case, petitioner had not paid any portion of petitioner’s              
          unpaid liability for 1988.                                                  
               Petitioner filed a return for her taxable year 1989 on April           
          24, 1990.  In that return, petitioner showed $1,661 as tax for              
          1989.  As of April 15, 1990, petitioner had a withholding credit            
          of $1,491 with respect to that tax.  On June 4, 1990, respondent            
          timely assessed the following for petitioner’s taxable year 1989:           
          Tax of $1,661; additions to tax under section 6651(a)(1) for                
          failure to file timely and section 6651(a)(2) for failure to pay            
          timely of $7.65 and $1.18, respectively; and interest of $2.70,             
          all of which respondent reflected in Form 4340.  On June 4 and              
          July 9, 1990, respondent sent petitioner a notice of balance due            
          with respect to her unpaid liability for 1989 of $170 in tax and            
          $8.83 in additions to tax, plus interest as provided by law on              
          those amounts.  As of the date of trial in this case, petitioner            
          had not paid any portion of petitioner’s unpaid liability for               
          1989.                                                                       
               On June 19, 1990, petitioner sent respondent the following             






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