Michael Sponberg - Page 6




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          and (4) petitioner’s account with respect to his taxable year               
          1985 with petitioner’s payment of $122.47 set forth above that              
          was made by levy from petitioner’s wages for his pay period that            
          ended August 20, 1991.                                                      
               Also included within the payments that petitioner made to              
          the IRS during the period March 20, 1996, through March 29, 1998,           
          were 15 $1,000 payments that petitioner believed respondent                 
          should have credited against his unpaid liability for each of his           
          taxable years 1987 and 1990.  However, as reflected in Form 4340            
          with respect to each of petitioner’s taxable years 1984 and 1985            
          and in respondent’s statement of petitioner’s account with                  
          respect to his taxable year 1986, respondent ultimately credited            
          petitioner’s 15 $1,000 payments as follows:                                 
















               4(...continued)                                                        
          dent collected by levy from petitioner’s wages for his pay period           
          that ended Aug. 8, 1991, and that respondent should have credited           
          that $652.14 as of Aug. 29, 1991, against petitioner’s unpaid               
          liability for his taxable year 1987.                                        





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