Linda Mitchell - Page 9

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               Petitioner presents in her claim alternative arguments as to           
          why interest on the 1994 tax deficiency should be abated.  These            
          arguments are lack of knowledge that interest was accruing and              
          inability to pay.  Petitioner’s arguments fail on the basis of              
          the record.                                                                 
          Lack of Knowledge                                                           
               Petitioner argues that she thought that she needed to pay              
          only the deficiency and penalty determined in the decision                  
          document and that she did not know to look at her nonmaster file            
          account to know that there was interest assessed.  Interest on a            
          Federal income tax liability generally begins to accrue from the            
          last date prescribed for payment of that tax and continues to               
          accrue, compounding daily, until payment is made.  See secs.                
          6601(a), 6622(a).  Petitioner, a tax return preparer by                     
          profession, admitted at trial that she knew that interest accrues           
          on unpaid taxes.  Therefore, petitioner’s lack-of-knowledge                 
          argument must fail.                                                         
               Petitioner’s nonmaster file transcript reports that                    
          petitioner received four notices regarding the balances in her              
          account, including accrued interest.  The Appeals officer                   
          testified that, even when petitioner’s account was in 53 status,            
          petitioner would have still received an annual notice reflecting            
          the 1994 balance due.  Petitioner’s claim that she had no                   
          knowledge of the accrued interest fails on the basis of the                 

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