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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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Last modified: May 25, 2011