Nora Aranda - Page 3

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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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