- 4 - All the above-mentioned income tax returns reflected balances due. Neither petitioner nor Mr. Ogonoski paid the balances due when they filed their returns for the taxable years 1989 through 1999. A substantial portion of the unpaid balances is attributable to Social Security self-employment tax on Mr. Ogonoski’s excavation business. There is no record evidence Mr. Ogonoski promised petitioner he would pay the tax liabilities reported on their returns. Some payments were subsequently made in respect of the amounts shown due on these returns. Respondent accepted as filed all the returns for the years in issue. The balances due, petitioner’s wages, and income tax and Medicare and Social Security payments withheld from petitioner’s wages, reflected on petitioner’s and Mr. Ogonoski’s joint income tax returns, were as follows: Medicare/Social Balance Petitioner’s Income Tax Security Tax Year Due Wages Withheld Withheld 1989 $8,943.18 $5,115.25 $67.87 $384.17 1990 7,696.89 4,966.80 -0- 379,96 1991 2,995.76 5,319.00 -0- 406.90 1992 5,474.30 3,355.96 32.75 256.76 1993 4,333.32 8,233.46 954.26 629.84 1994 2,242.57 14,104.65 1,151.04 1,079.05 1995 2,211.52 22,031.54 2,696.67 1,685.33 1996 3,023.28 25,302.31 3,476.39 1,935.49 1997 2,621.75 29,547.44 4,330.30 2,264.44 1998 3,647.39 33,519.15 5,336.74 2,598.56 1999 1,831.50 36,015.24 6,137.84 2,801.81 On the following dates, respondent assessed income tax, estimated tax and failure-to-pay penalties, and interest against petitioner and Mr. Ogonoski for the taxable years 1989 throughPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011