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This case is before the Court on respondent’s motion for
summary judgment under Rule 121. This proceeding arises from a
petition for judicial review filed in response to a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 sent to petitioners.
Some of the facts in this case have been stipulated and are
so found. Petitioners resided in Los Angeles, California, at the
time they filed their petition.
Petitioners received an extension to file their 1992 Form
1040, U.S. Individual Income Tax Return (return), to October 15,
1993. Petitioners then filed their 1992 return late on December
18, 1993. Petitioners received an extension to October 15, 1994,
and October 15, 1995, to file their 1993 and 1994 returns,
respectively. Petitioners then filed the tax returns late on
September 5, 1995, and October 10, 1995, respectively.
Petitioners received an extension to file their 1995 return to
October 15, 1996. Petitioners then filed their 1995 tax return
late on August 16, 1997.
As stated, petitioners timely filed extensions in which to
file their returns for 1992, 1993, 1994, and 1995 (the four
years). Petitioners then filed late joint returns for these four
years. They failed to pay all of the liabilities reported on
the returns. Respondent assessed the reported liabilities, along
with additions to tax and interest, for the respective years.
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