Theodore W. Banis, Jr. - Page 10

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               me by Nationwide Insurance Company.  Pursuant to a                     
               court order dated May 9, 1994, Nationwide Insurance                    
               Company was directed to pay directly to the trustee all                
               money owed me from my Agents’ Security Compensation                    
               Plan and Deferred Incentive Credits Plan [.] Monthly                   
               payments from Nationwide went directly to the trustee                  
               from 1994 through 1998 for disbursement by the trustee                 
               under the bankruptcy.  All taxes owed should have been                 
               paid by the Trustee.  The trustee’s final report shows                 
               that $69,336.26 was paid to the IRS for taxes.  Thus,                  
               the amounts you are showing as overdue should be a part                
               of this $69,336.26.                                                    
                    I have attempted to correct this matter many times                
               in the past few years.  I have received a “Closing                     
               Letter” dated April 3, 1998, indicating that all l996                  
               taxes have been paid (copy enclosed) and do not                        
               understand why I continue to receive notices that I                    
               still owe unpaid taxes for that year.                                  
               Appeals Officer Sansbury reviewed IDRS transcripts of                  
          petitioner’s account for 1990-96 and determined that $69,234 had            
          been credited to petitioner’s account for 1990-94.  The 1990-94             
          transcripts confirm the payment of $69,234 under the transaction            
          code 670, accompanied, in all but one case, by the description              
          “subsequent payment undesignated bankruptcy” and accompanied, in            
          that one case, by the description “subsequent payment”.  No                 
          payments by the trustee are reflected in the transcript of                  
          petitioner’s account for 1996.  In fact, the only payment                   
          reflected in the transcript for 1996 is $2,726 for withheld                 
          taxes.  The Form 4340, Certificate of Assessments and Payments,             
          for 1996 also reflects that there was no payment for that year              
          other than a credit for $2,726 of withheld taxes.                           








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