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Additional Additions to tax
Year income tax Sec. 6653(b) Sec. 6661 Interest
1984 $5,534.91 $2,464.87 $1,384.70 $1,997
1985 16,754.98 8,006.41 3,050.43 3,647
1986 28,848.86 22,157.87 6,528.77 3,190
On July 8, 1988, respondent issued a notice of deficiency
for 1984 and 1985 and a separate notice of deficiency for 1986.
Petitioner and Mr. Aranda did not file a petition in this Court
with respect to either notice. Because the deficiencies
determined in the notices of deficiency were less than what
respondent had assessed earlier as jeopardy assessments,
respondent abated portions of the jeopardy assessments on March
6, 1989. After taking the abatements into account, the income
tax deficiencies and additions to tax assessed with respect to
petitioner and Mr. Aranda for 1984, 1985, and 1986 were as
follows:
Additions to Tax
Year Deficiency Sec. 6653(b) Sec. 6661
19841 $3,361.16 $2,464.87 --
1985 12,201.72 8,006.41 $3,050.43
1986 26,115.08 22,157.87 6,528.77
1The parties concede that the 1984 tax liability is no
longer at issue. Petitioner failed to request relief for that
taxable year in her Form 8857, Request for Innocent Spouse
Relief.
Petitioner has paid $23,203.83 and $38,287.20 on the 1985 and
1986 tax liabilities, respectively.
On March 12, 1999, petitioner was granted a divorce from Mr.
Aranda. On May 19, 1999, petitioner filed Form 8857, Request for
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Last modified: May 25, 2011