- 3 -
Trust Fund Recovery Penalty and Income Tax Deficiencies
On September 3, 1992, respondent filed a Notice of Federal
Tax Lien for $9,536.28 against petitioner with respect to a trust
fund recovery penalty (the TFRP) under section 6672 for
employment tax periods ending September 30, 1989, December 31,
1989, and March 31, 1990.3
Petitioners filed their 1993 Federal income tax return on
April 15, 1994, showing tax due of $917.15, but remitted no
payment with the return. Petitioners filed their 1994 Federal
income tax return on July 8, 1996, showing tax due of $1,498, but
remitted no payment with the return. Petitioners filed their
1995 Federal income tax return on April 15, 1996, showing tax due
of $964, and, again, no payment was remitted with the return.4
Installment Agreement
In August 1996, petitioner called the Internal Revenue
Service (IRS) to discuss the payment of his existing tax
liabilities (the first call). During the first call, petitioner
spoke to an employee of the IRS whom he recalls as “Miss
Morrison” at one of the IRS’s automated collection sites (ACS).
3 The trust fund recovery penalty (TFRP) was assessed on
June 8, 1992, as a result of employment tax liabilities incurred
by Northern Colorado Travel while petitioner was its president.
4 Petitioners also filed a chapter 13 bankruptcy petition on
June 24, 1993, which was dismissed on Jan. 13, 1995; they
received a debt discharge in a chapter 7 proceeding on Mar. 27,
1996.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011