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petitioner’s Social Security number and the notation “1994 1040".
The $10,200 payment was applied by respondent to petitioners’
then outstanding 2000 tax liability.3
An administrative hearing was held on August 2, 2002.
During that hearing petitioner claimed that the 1994 tax
liability had been paid in full by the three checks previously
sent by petitioners to respondent in March 1996. As of the date
of the administrative hearing, petitioners had not filed tax
returns for 1995, 1997, 1998, 1999, or 2000. Consequently,
respondent would not consider an installment agreement with
respect to petitioners’ 1994 tax liability. Petitioners
subsequently filed a tax return for each of these years.
In August 2002, petitioners submitted a Form 433-A,
Collection Information Statement for Wage Earners and Self-
Employed Individuals. Petitioners listed their total monthly
income and living expenses as $10,320 and $7,611, respectively.
By letter dated August 8, 2002, petitioners notified respondent
that the $10,200 payment made on July 25, 2001, was intended to
be, and should have been, applied to their 1994 tax liability.
Respondent subsequently took the necessary steps to apply the
$10,200 payment to the 1994 tax liability.
3 At the time, it appeared that petitioners’ 1994 liability
had been paid in full.
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Last modified: May 25, 2011