- 6 - 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, petitionersPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011