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