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On February 11, 1999, petitioner filed his 1991 return, on
which he reported a tax liability of $1,589. On his 1991 return,
petitioner claimed that an overpayment in the amount of $10,218
was available for credit to other tax liabilities. On Form 9358,
filed with his 1991 return, petitioner requested that respondent
apply his April 18, 1991, estimated tax payment first to his 1991
income tax liability, and then to his 1992 income tax liability.
Respondent apparently acceded to this request as to 1991, since
$1,589 of the estimated tax payment was applied against the
liability shown on the delinquent 1991 return. A computer print
of petitioner’s IRS accounts reflects a 1992 liability for tax,
interest, and penalties, through March 8, 2000, of $8,525.68.
Beyond this, the record is silent as to payment of petitioner’s
1992 tax liability.
In mid-1999, petitioner filed delinquent Federal income tax
returns for his 1992, 1993, 1994, 1995, and 1997 tax years, with
each return showing a balance due.
On October 25, 1999, respondent issued to petitioner a
letter entitled “FINAL NOTICE--NOTICE OF INTENT TO LEVY AND
NOTICE OF YOUR RIGHT TO A HEARING” relating to petitioner’s
unpaid income tax liabilities for 1993, 1994, 1995, and 1997.
Thereafter, on November 22, 1999, petitioner sent Form 12153,
“Request for a Collection Due Process Hearing”, to respondent.
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Last modified: May 25, 2011