- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011