- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011