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liability for 1980 was fully paid as of May 4, 1992. Although
respondent collected a portion of petitioners’ taxes for 1981,
their tax liability for that year was not fully paid as of the
dates the petitions were filed in the instant cases.
B. Taxable Years 1990 and 1992
On December 2, 1991, petitioners filed a joint Federal
income tax return for 1990 reporting tax due in the amount of
$217,475. Petitioners failed to remit with their return the
amount reported to be due. On December 2, 1991, respondent
assessed the tax that petitioners reported due for 1990 and
statutory interest. Sec. 6201(a)(1).
Petitioners submitted to respondent a delinquent joint tax
return for 1992. Respondent reviewed the return and determined,
pursuant to the so-called math error provisions of section
6213(b), that petitioners were liable for tax in the amount of
$75,532, as well as for penalties and interest. On April 28,
1997, respondent assessed such tax, penalties, and interest for
1992.
C. Collection Litigation
On January 7, 2000, the United States filed suit against
petitioners in the United States District Court for the Eastern
District of Wisconsin (docket No. 00-C-0082) to reduce to
judgment the unpaid assessments entered against petitioners for
the taxable years 1981, 1990, and 1992. (For convenience, we
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