- 7 - 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 taxPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011