- 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011