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redetermination of the deficiency, addition to tax, and penalty.
On October 25, 1999, respondent assessed the deficiency, addition
to tax, penalty, and additional interest of $787.13, in the total
amount of $3,114.13.
On March 18, 1999, the taxpayers filed a joint income tax
return for the 1996 taxable year (1996 return). The 1996 return
showed a tax liability of $25,269, Federal income tax
withholdings of $16,148, and an amount owed of $9,121.
Respondent did not issue a notice of deficiency for the 1996
taxable year.
On September 17, 1999, petitioner made an inquiry with the
Problem Resolution Program (PRP) of the Problem Solving Office
(PSO) of the Internal Revenue Service (IRS) regarding the status
of the 1996 account. On September 20, 1999, the PSO responded
with an acknowledgment letter that either someone from the PSO
would contact the petitioner, or petitioner could contact the PRP
caseworker, Mrs. C. Ogle (Ms. Ogle). Thereafter, petitioner
spoke with Ms. Ogle, and taxpayers made payments in the amount of
$14,171.83 (tax payments) toward their tax obligations. These
payments are reflected on Form 4340 for both 1995 and 1996 as
miscellaneous payments.
On November 23, 1999, respondent applied $2,746.13 of the
tax payments to the taxpayers’ 1995 account. As reflected on
Form 4340 with respect to the taxpayers’ 1995 taxable year, this
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Last modified: May 25, 2011