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Court in which he disputed that he was liable for self-employment
taxes on income he received in 1987 and 1989 and for additions to
tax pursuant to section 6651(a)(1) for 1987 and 1989.
On June 24, 1998, the Court issued an opinion and entered a
decision in favor of respondent for the amounts set forth in the
notice of deficiency.2
On November 20, 1998, respondent assessed $3,777 of income
tax, a $358 addition to tax pursuant to section 6651(a)(1), and
$6,116.44 of statutory interest for 1987. Respondent also
assessed $6,500 of income tax, a $1,556 addition to tax pursuant
to section 6651(a)(1), and $6,542.53 of statutory interest for
1989.
On May 4, 1999, the U.S. Court of Appeals for the Second
Circuit affirmed the Court’s decision.
Payments
On June 21, 1994, petitioner mailed respondent a payment of
$6,681.22. On June 23, 1994, respondent applied the $6,681.22
payment to petitioner’s unassessed liabilities for 1987 and
1989--$1,431 to 1987 and $5,250.22 to 1989.
1993 Refund
On May 1, 1995, respondent sent petitioner a refund check of
2 In our Memorandum Opinion, we found that petitioner did
not file returns for 1987 and 1989. Wright v. Commissioner, T.C.
Memo. 1998-224, affd. without published opinion 173 F.3d 848 (2d
Cir. 1999).
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