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Tax liability $73,524
Tax assessed:
Paid $50,853.78
Not Paid 29,956.22
80,810
Deficiency (to be assessed) None
That there are additions to the tax due from the
petitioners under the provisions of I.R.C. � 6651(a)(1)
for the taxable years 1989, 1992, and 1993 in the a-
mounts of $7,172, $1,520, and $1,458, respectively.
That there are penalties due from the petitioners
under the provisions of I.R.C. � 6662(a) for the tax-
able years 1989, 1991, 1992, and 1993 in the amounts of
$2,165, $1,789, $426, and $3,923, respectively.
That there are no additions to the tax due from
the petitioners under the provisions of I.R.C.
� 6651(a)(1) for the taxable years 1990 and 1991.
That there is no penalty due from the petitioners
under the provisions of I.R.C. � 6662(a) for the year
1990.
At a time not disclosed by the record, petitioner and Mr.
Monsour jointly filed Form 1040 for their taxable year 1998 (1998
joint return). At the time of the trial in this case in Septem-
ber 2003, petitioner and Mr. Monsour had an unpaid liability of
$60,000 with respect to their 1998 joint return.
On February 12, 2001, petitioner filed with respondent Form
8857, Request for Innocent Spouse Relief (And Separation of
Liability and Equitable Relief), with respect to each of the
taxable years 1989, 1990, 1991, 1992, and 1993 (petitioner’s Form
8857). Petitioner attached the following statement to peti-
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