Michael Sponberg - Page 3




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                                                                  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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