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deficiency. On September 5, 1994, respondent assessed the $545
deficiency and $103.37 of accrued interest.
Petitioner filed his 1992 Federal income tax return late on
July 28, 1993. Respondent selected petitioner’s 1992 return for
an audit examination. On January 11, 1995, respondent mailed
petitioner a statutory notice of deficiency for his 1992 taxable
year determining a $1,193 income tax deficiency and a $189
penalty for late filing under section 6651(a)(1). On July 17,
1995, respondent assessed the deficiency, the late-filing
penalty, and accrued interest in the amount of $265.92. On the
same day, the late-filing penalty was abated leaving an unpaid
balance of $1,458.92 for 1992.
Joint Liabilities
Petitioners were married in 1993. Under cover of a letter
dated September 15, 1997, petitioners submitted their untimely
1994, 1995, and 1996 joint Federal income tax returns. These
returns were filed by respondent on September 29, 1997.
Petitioners reported tax due for 1994, 1995, and 1996 on their
returns in the amounts of $402.04, $402.03, and $1,480.66,
respectively.
On October 27, 1997, respondent assessed the 1994 income tax
liability, a late-filing penalty in the amount of $100, a failure
to pay tax penalty in the amount of $62.32, and accrued interest
in the amount of $128.35, for a total assessment of $692.71. On
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