- 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.
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