- 7 - on the second amended joint return of $79,073. Petitioner paid the income tax liability reported on the second amended joint return on or about November 17, 1994. With this payment, petitioner paid the 1989 income tax in full. Accrual of Interest on the 1989 Income Tax Liability Because petitioner and Apostle did not report the correct income tax liability on the original joint return, interest accrued under section 6601 on the full amount of the 1989 income tax liability from April 15, 1990, the due date of the original joint return, until June 12, 1992, the date on which petitioner paid $36,171 of the 1989 income tax liability (1990-1992 interest liability). Thereafter, interest continued to accrue on the remaining amount of the 1989 income tax liability until November 17, 1994, the date on which the 1989 income tax liability was paid in full (1992-1994 interest liability). Petitioner paid $8,690 of the 1990-1992 interest liability on August 21, 1992. Neither petitioner nor Apostle has paid any of the 1992-1994 interest liability. Consequently, under section 6601, interest continues to accrue on the remaining amount of the 1990-1992 interest liability and the entire 1992-1994 interest liability (collectively, these amounts of accrued interest are referred to as the “unpaid interest”). Neither petitioner nor Apostle was required by their divorce decree to pay any of the unpaid interest.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011