H&H Trim & Upholstery Co., Inc. - Page 3

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          that quarter.  Following a similar pattern, petitioner continued            
          to accrue employment tax liabilities for subsequent quarters,               
          including the first and fourth quarters of 1994 and the first               
          three quarters of 1996.                                                     
               In June of 1994, petitioner and respondent entered into an             
          agreement whereby, following a payment of $400 on June 15,                  
          petitioner agreed to make weekly payments of $250 until                     
          petitioner’s then-outstanding employment tax liabilities were               
          paid in full.  Payments of $400 and $600 were applied to                    
          petitioner’s employment tax liability for the fourth quarter of             
          1993 on November 8, 1996, and December 19, 1996, respectively.              
               In response to an inquiry made in a telephone conversation             
          that occurred during January of 1997, an employee of respondent             
          advised Mr. Halse that petitioner’s then-outstanding employment             
          tax liabilities were as follows:  Fourth quarter of 1993–-                  
          $6,088.36; first quarter of 1994--$3,679.45; fourth quarter of              
          1994--$435.69; first, second, and third quarters of 1996--                  
          $1,277.57.  On January 15, 1997, Mr. Halse delivered to                     
          respondent’s Sarasota office four certified checks in amounts               
          corresponding to the account balances provided to Mr. Halse by              
          respondent’s employee.  On January 16, 1997, the checks were                
          applied to the designated account balances for the above-                   
          referenced quarters.                                                        

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