121 T.C. No. 3
UNITED STATES TAX COURT
YVONNE E. THURNER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
SCOTT P. THURNER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 9971-01, 3586-02. Filed July 11, 2003.
On Jan. 30, 1991, the Court entered a decision in
docket No. 8407-87 redetermining Ps’ joint tax
liabilities for 1980 and 1981. In June 1991, R
assessed the taxes, additions to tax, and increased
interest as set forth in the above-referenced decision.
Ps’ joint tax liability for 1980 was fully paid as of
May 4, 1992. A portion of Ps’ joint tax liability for
1981 remained unpaid as of the dates the petitions were
filed in these cases.
On Dec. 2, 1991, Ps filed a joint Federal income
tax return for 1990 reporting tax due. No remittance
was made with this return. Ps submitted a delinquent
joint return for 1992, and R made adjustments to this
return. R subsequently assessed taxes and penalties
due from Ps for 1990 and 1992.
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