- 4 - 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 moneyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011