- 4 -
miscellaneous payment, combined with a $391.23 overpayment credit
relating to the taxpayers’ 1998 taxable year, satisfied the
taxpayers’ liability for the 1995 taxable year.1 On November 23,
1999, taxpayers had an overpayment credit balance of $15.63.
On November 29, 1999, respondent assessed tax of $25,269, an
addition to tax for late filing of $2,207.72, and interest of
$2,594.84 relating to the 1996 taxable year. On December 29,
1999, respondent applied $11,425.70 of the tax payments to the
taxpayers’ 1996 account. As reflected on Form 4340 with respect
to the taxpayers’ 1996 taxable year, the taxpayers’ account for
the 1996 taxable year received the following credits: $290.14
overpayment credit from the 1995 taxable year that the taxpayers
elected to apply to 1996; $15.63 overpayment credit balance from
the 1995 taxable year as described above; and $455.77 overpayment
credit from the 1998 taxable year. As of January 24, 2003, the
taxpayers’ balance due for the 1996 taxable year was $1,736.32.
On July 18, 2001, respondent mailed to the taxpayers a Final
Notice - Notice of Intent to Levy and Notice of Your Right to a
Hearing (final notice) for the 1995 and 1996 taxable years. The
final notice informed the taxpayers of respondent’s intention to
levy under section 6331 and of the taxpayers’ right to Appeals
Office consideration. The final notice also included a copy of
1 From October 25 to November 23, 1999, an increased
addition to tax and interest accrued in the amount of $7.60.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011