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those adjustments resulted in the following additional tax,
penalties, and interest:
1993 1995
Alternative minimum tax $3,221.00 $1,510.00
Sec. 6662 accuracy-related penalty 644.20 302.00
Interest computed until Mar. 5, 1998 1,548.23 330.66
5,413.43 2,142.66
As to 1993, the revenue agent listed on the Form 4549-CG and the
supporting schedules that he had determined the following
adjustments as increases or decreases to the taxable income
petitioners reported on their 1993 return:
Capital gain $630,764
Sec. 465 limited at risk 6,880
Itemized deductions 1,983
NOL carryback from 1994 (166,364)
NOL carryback from 1996 (301,269)
171,994
The revenue agent’s letter to Bellavia advised Bellavia to
discuss the adjustments with petitioners and, if acceptable to
them, to have them sign and date the Form 4549-CG and return it
to the revenue agent. The letter stated that “It would be
appreciated if they [petitioners] would remit the balance due of
$7,556.09 [$5,413.43 + $2,142.66] at that time.” On March 3,
1998, petitioners signed the Form 4549-CG and returned it to the
revenue agent with a check for $7,556.09. The Form 4549-CG
stated immediately above their signatures:
Consent to Assessment and Collection –- I do not
wish to exercise my appeal rights with the Internal
Revenue Service or to contest in United States Tax
Court the findings in this report. Therefore, I give
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Last modified: May 25, 2011