Gunter R. and Jay R. Wall - Page 3

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          The issue for decision is whether respondent may proceed with               
          collection of tax liabilities for the year 1999.                            
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  Petitioners resided in              
          Louisville, Kentucky, on the date the petition was filed in this            
          case.                                                                       
               Petitioner husband (petitioner) currently is employed as a             
          teacher at Indiana University Southeast and the Kentucky                    
          Community College Technical Educational System, and he teaches              
          military classes at Fort Knox.  Petitioner previously had been              
          employed at the Sears credit card center in Louisville in                   
          addition to his teaching positions, but he no longer is employed            
          by Sears.  Petitioner wife is not employed.  Both petitioners               
          receive Social Security benefits.                                           
               Petitioners filed Federal income tax returns in each of the            
          years 1989 through 2001.  In each year the return reflected an              
          amount due after subtracting withheld amounts from the total tax            
          liability.  Petitioners did not remit payment for the outstanding           
          liability in any of the years.  In taxable year 2001, the last              
          year for which return information is available, petitioners                 
          reported $44,591 in wage income and $13,269 in Social Security              
          benefits, an adjusted gross income of $56,175, and a tax                    
          liability of $5,021.  Only $1,896 had been withheld from                    






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