- 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