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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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