Steven Jay Wolk - Page 3

                                        - 2 -                                         
               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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