Steven Jay Wolk - Page 6

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               Upon receipt of these documents, respondent applied $1,829             
          and $817 of the 1987 overpayment to petitioner’s 1989 and 1990              
          tax liabilities, respectively.  The rest, $3,995, remained as an            
          overpayment from 1987.  As a result, respondent issued two refund           
          checks to petitioner:  (1) $780.544 on November 30, 1992, and (2)           
          $3,3005 on December 7, 1992.  Instead of negotiating these refund           
          checks, petitioner placed them in a file cabinet.  When the time            
          in which the checks could be negotiated expired, respondent                 
          issued a third check to petitioner on April 18, 1994, in the                
          amount of $4,080.54.  Again petitioner failed to timely negotiate           
          the third refund check.  Respondent issued a fourth refund check            
          on February 5, 1996, in the amount of $5,497.36,6 which                     
          petitioner negotiated.                                                      
               On June 29, 2001, respondent issued to petitioner a Notice             
          of Federal Tax Lien Filing and Your Right to a Hearing Under IRC            
          6320.  Petitioner timely filed a Request for a Collection Due               
          Process Hearing.  On June 5, 2002, respondent issued a Notice of            
          Determination Concerning Collection Action(s) Under Section 6320            
          to petitioner determining, inter alia, that all legal and                   



               4   Balance remaining from the $3,341 overpayment resulting            
          from the 1989 NOL, minus the 1989 and 1990 tax liabilities, plus            
          interest.                                                                   
               5   The overpayment resulting from the 1990 NOL.                       
               6   The $3,995 overpayment plus interest.                              





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