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collection by levies of petitioners’ unpaid tax for 1984 and Mr.
Maloney’s unpaid tax for 1995 should be sustained.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
Perkiomenville, Pennsylvania, at the time of filing the petition.
On January 22, 1996, respondent issued a notice of
deficiency to petitioners in which he determined a deficiency and
additions to tax for their 1984 taxable year. Petitioners filed
a petition with the Tax Court disputing respondent’s
determinations. In those proceedings, the parties stipulated the
amount of credits for Federal income tax withholdings, including
FICA taxes. The parties reached a basis of settlement in that
case, stipulating the deficiency for 1984. The Tax Court entered
its decision on September 15, 1998, incorporating respondent’s
computation for decision. The computation for decision
incorporated the stipulated deficiency for 1984 and stated that
there were additional withholding credits of $5,306 for 1984. On
February 2, 1999, respondent assessed the deficiency and credited
petitioners for the additional withholding credits for 1984.
Mr. Maloney filed an individual Federal income tax return
for 1995 listing his filing status as married filing separate.
He reported a net profit of $4,828 and $446 in self-employment
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