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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.
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