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Background
The petition in this case was timely filed in response to a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 with respect to the taxable years 1992
through 1997. At the time the petition was filed herein,
petitioner resided in Newton, New Jersey. While the tax returns
are not part of the record in this case, our recitation of the
background of the case is based in part upon IRS transcripts of
account. The facts do not appear to be in dispute.
Petitioner’s 1990 and 1991 Federal income tax returns were
filed September 20, 1993. The returns each reflected a balance
due after withholding; the taxes shown on the returns, plus
interest and estimated tax penalty, were assessed. The balances
due for 1990 and 1991 were ultimately paid in full by January
1999, after periodic payments and overpayment offsets from years
after 1991.
Petitioner’s 1992 through 1996 returns were filed as
follows:
Year Date of Filing of Return
1992 Oct. 10, 1994
1993 Nov. 28, 1994
1994 Apr. 27, 1998
1995 July 27, 1998
1996 July 27, 1998
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