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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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