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reversals when the two checks were returned for insufficient
funds.5
After applying the $10,200 payment to petitioners’ 1994
taxable year, which respondent has agreed to do, a portion of
petitioners’ 1994 tax liability remains outstanding.
Accordingly, respondent’s determination to proceed with
collection of petitioners’ outstanding 1994 Federal income tax
liability is sustained.
To reflect the foregoing,
Decision will be
entered for respondent.
5 The transcript of petitioners’ 1994 taxable year does not
reflect the $10,200 payment by petitioners in July 2001 that was
applied to petitioners’ 2000 taxable year.
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Last modified: May 25, 2011