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issued a check in the amount of $19,980.69 to the Internal
Revenue Service in response to the notice of levy.
On January 7, 1997, the aforementioned $19,980.69 was
allocated to petitioner and Mr. Leissner’s 1986 and 1987 tax
liabilities as follows: $8,710.27 was applied to the 1986 tax
liability and $11,270.42 was applied to the 1987 tax liability.
The parties stipulated that the application of $11,270.42 to
the 1987 tax liability fully paid the tax, penalties, and
interest due for 1987. The parties agree that a lien filing fee
of $32 relating to 1987 was not paid along with the tax,
penalties, and interest for 1987. The parties do not agree as to
whether the lien filing fee is part of petitioner’s 1987 tax
liability.
On March 3, 1997, petitioner filed for Chapter 7 bankruptcy
relief. On July 9, 1997, petitioner received a personal
discharge from liability for her 1986 and 1987 income tax
liabilities.
Mr. Leissner did not pay the 1986 tax liabilities prior to
July 22, 1998.
As of July 22, 1998, petitioner and Mr. Leissner had an
outstanding income tax liability of $65,905.43 for 1986. As of
July 22, 1998, a lien filing fee of $32 was outstanding for 1987.
On November 30, 1998, petitioner filed Form 911, Application
for Taxpayer Assistance Order, seeking a refund of the money
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