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private law practice has consisted of criminal work. Petitioner
failed to pay employment taxes pertaining to his law practice,
and the Internal Revenue Service (IRS) assessed those taxes.
Petitioner filed delinquent income tax returns for 1996-99
after he was contacted by a representative of the IRS.
Petitioner and his former wife filed joint returns for 1996-98.
Petitioner filed his return for 1999 as single. He failed to
remit all the taxes shown as due on the returns. The IRS
assessed additions to tax for late filing under section
6651(a)(1), late payment under section 6651(a)(2), and failure to
pay estimated tax under section 6654. The returns were filed and
assessments for taxes, interest, and additions to tax were made
on the following dates:
Year Date Return Filed Assessment Date
1996 5/7/01 9/17/01
1997 5/7/01 9/24/01
1998 5/7/01 9/10/01
1999 4/16/01 11/19/01
Petitioner and the IRS entered into an installment agreement
in connection with the collection of petitioner’s tax liability.
This agreement covered both petitioner’s income and employment
tax liabilities, as well as additions to tax and interest.
Petitioner defaulted on his agreement after making two monthly
payments.
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Last modified: May 25, 2011