Stephen and Patricia Lindsey - Page 3




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          Background                                                                  
               On July 13, 1993, petitioners filed a petition for                     
          redetermination with the Court (assigned docket No. 14904-93)               
          challenging a notice of deficiency that respondent issued to them           
          for the taxable year 1989.  See sec. 6213(a).  On May 17, 1995,             
          the Court entered a decision in docket No. 14904-93 pursuant to             
          agreement of the parties.  The decision provided that petitioners           
          were liable for a deficiency in income tax in the amount of                 
          $51,161 and an accuracy-related penalty under section 6662(a) in            
          the amount of $10,232.20.                                                   
               On March 4, 1997, petitioners executed a Form 4549, Income             
          Tax Examination Changes, in which they agreed to deficiencies in            
          their Federal income taxes for 1991, 1992, and 1993 in the                  
          amounts of $211,077, $258,223, and $192,048, respectively.                  
               On March 4, 1999, respondent issued to petitioner Stephen              
          Lindsey a Final Notice/Notice of Intent to Levy and Notice of               
          Your Right to a Hearing.  This notice stated that petitioner owed           
          Federal income tax, penalty, and interest for 1989, 1990, 1991,             
          1992, and 1993 in the amounts of $145,261.58, $278,199.30,                  
          $393,398.51, $448,778.08, and $312,634.68, respectively, and that           
          respondent was preparing to collect the amounts due by levy.  On            
          March 5, 1999, respondent issued to petitioner Patricia Lindsey a           
          Final Notice/Notice of Intent to Levy and Notice of Your Right to           








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