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Respondent issued a Notice Of Determination Concerning
Collection Action(s) Under Section 6320 to petitioner for unpaid
Federal income taxes and related liabilities in the following
amounts:
Year Liability1
1991 $6,070.14
1992 2,360.67
1994 .28
1995 .54
1996 1,557.39
1 Amounts computed through May 31, 2002. The amounts for
the 1991, 1992, and 1996 taxable years comprise unpaid Federal
income taxes, additions to tax for failure to timely file Federal
income tax returns and failure to pay Federal income taxes under
sec. 6651(a)(1) and (2), and interest.
The unpaid liabilities for the 1994 and 1995 taxable years
reflect unpaid interest calculated for 2 days. Respondent levied
upon petitioner’s bank account on Sept. 15, 1998, for payment of
petitioner’s 1994 and 1995 tax liabilities and interest
calculated through that date. Respondent received payment on
Sept. 18, 1998. Petitioner did not raise any issue with respect
to the unpaid interest amounts for 1994 and 1995 in the petition
filed with this Court, and, thus, these years are not before the
Court.
After concessions,2 the issues are (1) whether the period of
limitations on assessment bars respondent from collecting the
1991 and 1992 tax liabilities, (2) whether respondent correctly
issued refund checks to petitioner instead of applying an
overpayment to petitioner’s 1990 estimated tax payments, and (3)
2 Petitioner concedes the amount of Federal income taxes
due and the additions to tax for failure to timely file Federal
income tax returns under sec. 6651(a)(1) for the 1991, 1992, and
1996 taxable years.
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