Louise Demirjian - Page 7

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          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.                                                            






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