Cynthia A. Bell - Page 7

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                  As shown above, petitioner filed her 1998 return on                 
             April 17, 2002, approximately 32 months after it was due.                
             The return reported tax in the amount of $7,914.  On                     
             April 24, 2002, more than 36 months after payment of the                 
             tax was due, petitioner paid $8,273, or $359 more than the               
             tax shown on the return.  The record does not explain the                
             nature of this additional amount.                                        
                 The tax reported on petitioner’s return for 1998 was                
             due and unpaid from April 15, 1999, until April 24, 2002.                
             By July 8, 2002, when respondent assessed the tax reported               
             on petitioner’s delinquent 1998 return, interest of                      
             $2,206.97 had accrued on the tax reported on the return                  
             (i.e., $2,627.36, total interest assessed, less $420.39,                 
             interest related to the addition to tax under section                    
             6654(a)(2) that was later reversed).  Petitioner paid $359               
             of that amount (i.e., $8,273, total payment, less $7,914,                
             tax shown on the return) on April 24, 2002, when she filed               
             her delinquent return and $63 was offset by a credit on                  
             October 21, 2003.  The balance, $1,784.97, continued to                  
             accrue interest from July 8, 2002, to March 29, 2004, when               
             petitioner paid $1,914.16, the balance of $1,784.97, plus                
             additional assessed interest of $129.19.                                 
                  In passing, we note that the transcript of                          
             petitioner’s account for 1998 shows that additions to tax                






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