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