122 T.C. No. 22 UNITED STATES TAX COURT WILLIAM F. URBANO AND FLOTA L. URBANO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14466-02L. Filed June 10, 2004. Following R’s audit of Ps’ 1993 through 1996 Federal income tax returns, R’s revenue agent (A) prepared a Form 4549-CG, Income Tax Examination Changes, that listed $7,556.09 as the total amount of Federal income taxes, penalties, and interest Ps owed for those years. Ps signed the form, consenting to R’s immediate assessment and collection of the $7,556.09 and waiving their right to challenge in this Court the findings of A contained in that form, and delivered the signed form to A with a check for the stated amount. Subsequently, R determined that A had understated the interest due for 1993 by prematurely taking into account net operating loss (NOL) carrybacks to that year in disregard of sec. 6601(d)(1), I.R.C. R determined that Ps were liable for recalculated interest of $39,558.63 for 1993, instead of $1,548.23 as originally calculated by A, and filed a notice of Federal tax lien to secure Ps’ payment of $31,455.49 of that interest considered by R still to be owed for 1993 as of the time of the lien’s filing. At the hearingPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011