- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011