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liability bars granting petitioner’s request for relief from
joint and several liability, pursuant to section 6015,1 for 1995.
Background
On or about April 15, 1996, petitioner and her husband,
Thomas E. Hall, requested an extension to file their joint
Federal income tax return for 1995. On this same date,
respondent applied a withholding credit of $19,079 to their
account for 1995.
On or about October 27, 1997, petitioner and her husband
filed a joint return for 1995 (joint return). They reported a
tax due of $20,949. Accordingly, after application of the
$19,079 withholding credit, there was a balance due of $1,870.
On December 8, 1997, respondent assessed the tax reported on
the joint return, a “late filing penalty” of $420.75, a “failure
to pay tax penalty” of $187, and “interest assessed” of $347.14
(1995 tax liability).
On or about April 15, 1999, petitioner filed a return for
1998 claiming a $54 refund due (1998 overpayment). That same
date, respondent applied petitioner’s 1998 overpayment to the
outstanding balance on the 1995 tax liability.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code.
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