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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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