- 3 -
Total
Year Tax Additions to Tax Interest Liability
1984 $6,266 $1,823.10 $4,203.66 1$12,306.76
1985 9,100 1,414.15 10,113.61 20,627.76
1986 886 327.49 621.71 21,845.20
1Form 4340 with respect to petitioner’s taxable year 1984
also reflects a $14 charge for “FEES AND COLLECTION COSTS”,
making the total liability for that year $12,306.76.
2Respondent’s statement of petitioner’s account with respect
to his taxable year 1986 also reflects a $10 “COLLECTION CHARGE-
LIEN FEE”, making the total liability for that year $1,845.20.
On December 6, 1993, and October 30, 1993, respectively,
petitioner filed Forms 1040 for his taxable years 1987 (1987
return) and 1990 (1990 return), the two years to which the
collection action at issue relates. As reflected in Form 4340
with respect to each of petitioner’s taxable years 1987 and 1990,
respondent assessed on January 3, 1994, and December 6, 1993,
respectively, the following amounts of tax, additions to tax, and
interest:
Total
Year Tax Additions to Tax Interest Liability
1987 $3,911 $1,857.73 $3,475.41 $9,244.14
1990 1,954 529.10 386.15 2,869.25
Petitioner made certain payments to the Internal Revenue
Service (IRS) that respondent ultimately2 credited to
2On various occasions during 1995 through at least 1998,
petitioner and one or more of respondent’s representatives had
discussions regarding at least certain of his taxable years
discussed herein, and respondent made various corrections,
including so-called reversals, to petitioner’s accounts with
respect to his taxable years 1984, 1985, 1986, and 1987. In
describing petitioner’s accounts with respect to certain of his
(continued...)
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