Michael Sponberg - Page 5




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           Petitioner’s Pay Period Ended       Amount Collected by Levy               
                      05/03/91                         $706.14                        
                      05/20/91                        706.14                          
                      06/05/91                        706.14                          
                      06/20/91                        706.14                          
                      07/05/91                        706.14                          
                      07/19/91                        706.14                          
                      08/08/91                        706.14                          
                      08/20/91                         122.47                         
               As reflected in Form 4340 with respect to each of peti-                
          tioner’s taxable years 1984 and 1985, respondent ultimately                 
          credited:  (1) Petitioner’s accounts with respect to his taxable            
          years 1984 and 1985 with petitioner’s payments totaling $1,277.20           
          and $1,547.36, respectively, consisting of each of the $706.14              
          payments set forth above that were made by levy from petitioner’s           
          wages for his pay periods that ended May 3, May 20, June 5, and             
          June 20, 1991; (2) petitioner’s account with respect to his                 
          taxable year 1985 with petitioner’s payments totaling $1,412.28,            
          consisting of each of the $706.14 payments set forth above that             
          were made by levy from petitioner’s wages for his pay periods               
          that ended July 5 and July 19, 1991; (3) petitioner’s account               
          with respect to his taxable year 1985 with $54 of petitioner’s              
          payment of $706.14 set forth above that was made by levy from               
          petitioner’s wages for his pay period that ended August 8, 1991;4           


               4Sometime before the trial in this case, respondent con-               
          ceded, and on brief respondent reaffirms respondent’s concession,           
          that respondent did not credit to petitioner’s account with                 
          respect to any taxable year $652.14 of the $706.14 that respon-             
                                                             (continued...)           





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