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On June 1, 1999, petitioners filed an untimely 1994 joint
Federal income tax return (the 1994 return) on which they
reported an income tax liability of $18,524. Withholding credits
of $9,155, were applied against this liability, but no other
payments were made with the return. On February 7, 2000, the tax
reported on petitioners’ 1994 return, related additions to tax,
and interest were assessed (the 1994 tax liability).
On April 27, 2001, respondent issued to petitioners a Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing, for the unpaid balance of their 1994 tax liability. On
May 3, 2001, respondent issued to petitioners a Notice of Federal
Tax Lien Filing and Your Right to a Hearing Under IRC 6320. On
May 8, 2001, respondent filed a Notice of Federal Tax Lien (tax
lien notice) with the Recorder of Deeds, St. Clair County,
Belleville, Illinois, with respect to the 1994 tax liability.
During May 2001, petitioners sent to respondent two checks
in the amounts of $11,859 and $10,000, designated to be applied
to their 1994 tax liability. Both checks were subsequently
dishonored for insufficient funds. On June 3, 2001, before
receiving notice that the checks had been dishonored, respondent
released the tax lien notice. The release stated, in part, that
petitioners had satisfied their 1994 tax liability.
On or about July 25, 2001, petitioners sent to respondent a
money order in the amount of $10,200. The money order included
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