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Background
The record establishes and/or the parties do not dispute the
following.
Petitioner resided in Prospect, Connecticut, at the time she
filed the petition in this case.
On April 15, 2001, petitioner filed a Federal income tax
(tax) return for her taxable year 2000 (2000 return). In her
2000 return, petitioner reported total income of $628,613,
taxable income of $608,188, total tax of $223,186, tax withheld
of $87,586, and tax due of $135,600. Petitioner did not remit
with that return payment of the tax shown due.
On May 28, 2001, respondent assessed petitioner’s tax, an
addition to tax under section 6651(a)(2),2 and interest as pro-
vided by law for her taxable year 2000. On July 23, 2001,
respondent credited $300 to petitioner’s account for that taxable
year. On the same date, respondent assessed an additional
addition to tax under section 6651(a)(2) and interest as provided
by law for petitioner’s taxable year 2000. On March 10, 2003,
respondent applied an overpayment credit of $1,452 for peti-
tioner’s taxable year 2002 to petitioner’s taxable year 2000.
(We shall refer to any unpaid assessed amounts, as well as any
accrued and unassessed interest as provided by law, for peti-
2All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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Last modified: May 25, 2011