- 3 -
Background
The record establishes and/or the parties do not dispute the
following:
A. Petitioner’s Tax Liabilities for 1997 and 1998
On or about August 19, 1998, Morris Tabak (petitioner) filed
with respondent a Form 1040, U.S. Individual Income Tax Return,
for the taxable year 1997. On the return, petitioner reported
adjusted gross income of $75,301 and a tax liability of $13,023,
which respondent assessed. Because petitioner paid only $0.58 of
the reported liability, respondent also assessed interest, an
addition to tax under section 6651(a)(2) for failure to pay tax,
and an addition to tax under section 6654(a) for failure to pay
estimated tax. Notice and demand for payment was sent to
petitioner on November 9, 1998.
On or about August 18, 1999, petitioner filed with
respondent a Form 1040, U.S. Individual Income Tax Return, for
the taxable year 1998. On the return, petitioner reported
adjusted gross income of $79,219 and a tax liability of $14,429,
which respondent assessed. Because petitioner paid only $138 of
the reported liability, respondent also assessed interest, an
addition to tax under section 6651(a)(2) for failure to pay tax,
and an addition to tax under section 6654(a) for failure to pay
estimated tax. Notice and demand for payment was sent to
petitioner on September 20, 1999.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011