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credited petitioner’s account as follows:
Assessment, Payment, Assessment
Explanation of Other Debits Credit Date (23C,
Date Transaction (Reversal) (Reversal)RAC 006)
Adjusted gross income
22,419.00
Taxable income
13,016.00
10-30-93 Return filed and tax $1,954.00 12-06-93
assessed
89211-306-95415-3 199347
10-30-93 Withholding and excess FICA $573
04-15-91 Extension of time to file
ext. date 08-15-91
08-11-91 Extension of time to file
ext. date 10-15-91
10-30-93 Payment with return 516
Late filing penalty 310.73 12-06-93
199347
Failure to pay tax penalty218.37 12-06-93
199347
Interest assessed 386.15 12-06-93
199347
08-08-94 Federal tax lien
05-28-96 Collection statute
extension to 12-31-08
03-12-99 Legal/bankruptcy suit
pending
12-06-93 Statutory notice of balance
due
12-27-93 Statutory notice of intent
to levy
Balance $1,780.25
On January 29, 1999, respondent issued to petitioner a final
notice of intent to levy (notice of intent to levy) with respect
to, inter alia, petitioner’s taxable years 1987 and 1990.5 That
notice stated in pertinent part:
Your Federal tax is still not paid. We previously
asked you to pay this, but we still haven’t received
your payment. This letter is your notice of our intent
5The notice of intent to levy also applied to petitioner’s
taxable year 1988. Petitioner does not raise any issues with
respect to that year in this case.
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Last modified: May 25, 2011