- 2 - Respondent issued to petitioners a Notice Of Determination Concerning Collections Action(s) Under Section 6320 and/or 6330 for unpaid Federal income taxes and related liabilities for the taxable years 1992 and 1993 in the amounts (per collection notices dated March 4, 2002) of $9,214.97 and $4,042.66, respectively. The issues for decision are: (1) Whether petitioners are liable for the unpaid Federal income taxes reported on their 1992 and 1993 delinquent income tax returns. We hold that they are. (2) Whether petitioners are liable for (a) additions to tax under section 6651(a)(1) for failure to timely file their 1992 and 1993 income tax returns; (b) additions to tax under section 6651(a)(2) for failure to timely pay the unpaid tax reported on their 1992 and 1993 income tax returns; (c) an addition to tax under section 6654(a) for failure to pay estimated tax in 1993; and (d) interest in respect of their unpaid income tax and related liabilities for the taxable years 1992 and 1993. We hold that they are. (3) Whether respondent abused his discretion in determining that the levy action against petitioners may proceed. We hold that he did not.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011