Nicholas J. and Diane L. Palihnich - Page 6

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          petitioners again about their 1981-82 amended returns until early           
          1998.                                                                       
               3.   Petitioners’ Payment of Tax                                       
               In 1986-90 and 1992, respondent applied substantial                    
          overpayments and credits from 1980, 1982, and 1985-87 to                    
          petitioners’ tax liability for 1981.  Respondent also applied the           
          $14,193 in withholding credits that petitioners had reported on             
          their 1981 return to their 1981 tax liability.                              
               In October 1987, petitioners paid their nearly $76,000 tax             
          liability for 1982.  They expected that, because they had claimed           
          NOLs on their 1981-82 amended returns and made full payment for             
          1982, respondent would apply overpayments and withholding credits           
          of about $33,000 from 1985-87 to 1980 rather than to 1981 or                
          1982.  Petitioners believed that, after the filing of their 1981-           
          82 amended returns, the paying of the $76,000 liability for 1982,           
          and the application of overpayments to 1980, they would have                
          fully paid all tax liabilities asserted by respondent relating to           
          their White Rim investment.                                                 
               Respondent sent to petitioners notices of tax lien for 1981            
          on April 8, 1988, and June 19, 1991, a final notice of intent to            
          levy for 1981 on June 22, 1992, and a certificate of release of             
          Federal tax lien for 1981 on August 27, 1992.                               
               Respondent did not contact petitioners further about their             
          1980-83 tax years until 1997.  From 1987 to 1997, petitioners               






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