Charles Wendell Harkey, Sr. and Barbara Anne Harkey - Page 3

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               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.                                                            









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