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that the Internal Revenue Service (IRS) collected moneys from
third parties who had assets belonging to his professional
corporation and that excess collections were or should have been
applied to his personal tax liabilities. Unless otherwise
indicated, all section references are to the Internal Revenue
Code in effect for the years in issue.
Background
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioner resided in Philadelphia, Pennsylvania, at the time
that he filed his petition.
On or about November 7, 1989, petitioner stipulated to a
decision in this Court for his taxable years 1978 through 1983 as
follows:
ORDERED and DECIDED: That there are deficiencies
in income tax due from the petitioner for the taxable
years 1978, 1979, 1980, 1981 and 1982 in the amounts of
$978.00, $535.00, $6,323.00, $4,775.00 and $4,592.00,
respectively;
The decision also provided that there was an addition to tax
due from petitioner for 1981 under section 6651(a)(1) in the
amount of $1,411. As of the time that the notice of lien
involved in this case was filed, the deficiencies for 1978 and
1979 had been paid. The balances due from petitioner for 1980,
1981, and 1982 were $15,853.85, $14,267.46, and $9,422.95,
respectively.
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