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Petitioners object to respondent’s proposed collection activity
upon the ground that their 1994 Income tax liability has been
fully paid.
Background
Some of the facts in this case have been stipulated and are
so found. At the time the petition was filed, petitioners
resided in O’Fallon, Illinois. References to petitioner are to
Philip L. Eckert.
For years prior to 1994 petitioners owned 100 percent of the
shares of, and operated Southwestern Illinois Family and
Children’s Testing and Therapy Clinic, Inc. (Southwestern). For
periods during 1992 through 1995, Southwestern had unpaid Federal
employment tax liabilities that totaled $26,000 (employment tax
liabilities).2
During March 1996, petitioner delivered to respondent three
checks in the amounts of $10,000, $15,000, and $1,000, for a
total of $26,000. Each of the three checks contained
petitioner’s Social Security number and the notation “Pay only to
IRS”. None of the checks specifically identified the liability
to which the check related. Respondent applied the $26,000
received from petitioner to Southwestern’s $26,000 unpaid
employment tax liabilities.
2 All amounts are rounded to the nearest dollar.
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