- 25 - taxable year of $3,126.40. Petitioners also allege that a $2,564 refund was due for their 2001 taxable year, and that respondent applied that refund against the deficiencies in the instant case. Petitioners further allege that respondent notified them in a letter, dated March 28, 2002, that a $4,215 overpayment had been applied against the deficiencies in their 1991, 1992, and 1993 taxable years. Respondent’s notice of determination indicated that the liabilities shown on the final notice of intent to levy for petitioners’ 1992 taxable year were based on their tax returns. Respondent’s final notice of intent to levy showed that petitioners’ liabilities for their 1992 taxable year totaled $2,365.11, which reflects an assessed balance of $1,968.42 and statutory additions of $396.69. The Appeals officer’s supporting statement and the notice of determination indicate that those liabilities consisted of interest that had accrued on taxes reported on petitioners’ original and amended returns. The Appeals officer also indicated that “Generally, the taxpayer full [sic] paid the tax but has not paid the interest.” Petitioners reported a tax liability of $42,714.42 on their final amended 1992 tax return, and petitioners have paid at least that amount for their 1992 taxable year. However, the April 4, 2000 notice of deficiency indicates that the income tax for petitioners’ 1992 taxable year was $39,498.02. Respondent did not determine a deficiency in income tax for that year.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011