- 3 - 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 toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011