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do so, other than as mentioned in the following paragraph.
On June 3, 1997, and July 7, 1997, respondent applied
overpayment credits from petitioners’ account for the taxable
year 1990 in the amounts of $63.25 and $200, respectively, to
petitioners’ outstanding liability for 1992. Subsequently, on
August 12, 1997, respondent posted another $200 payment to
petitioners’ account for 1992. Other than the foregoing, no
credits or payments have been made to petitioners’ account for
1992.
B. Petitioners’ Liability for 1993
On June 17, 1994, petitioners filed Form 1040 for 1993, some
2 months after its due date. See sec. 6072(a).
On their 1993 income tax return, petitioners reported total
tax of $1,586, total payments of $0, and amount owed of $1,652.2
Petitioners did not enclose payment with their return of any part
of the liability reported thereon.
On July 25, 1994, respondent assessed against petitioners
income tax in the amount of $1,586, an addition to tax under
section 6654(a) for failure to pay estimated tax in the amount of
$66, an addition to tax under section 6651(a)(1) for failure to
timely file in the amount of $214.11, an addition to tax under
section 6651(a)(2) for failure to timely pay in the amount of
$31.72, and interest in the amount of $36.46. Also on July 25,
2 The amount owed included $66 for “estimated tax penalty”.
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Last modified: May 25, 2011