Cynthia A. Bell - Page 8

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             under section 6654(a)(1) in the amount of $1,780.65 and                  
             under section 6654(a)(2) in the amount of $989.25 were                   
             assessed on July 8, 2002, and were reversed on July 8,                   
             2002, and October 21, 2002, respectively, along with the                 
             interest related thereto in the amount of $420.39, and                   
             that a credit of $63 was applied to petitioner’s account                 
             on October 21, 2003.                                                     
                  The certified transcript for tax year 1998 also shows               
             that on July 8, 2002, and on October 21, 2002, statutory                 
             notices of balance due were issued to petitioner.  The                   
             balance of petitioner’s account on July 8, 2002, was                     
             $5,038.26 (i.e., - $8,273 + $7,914 + $1,780.65 + $989.25 +               
             $2,627.36).  The balance of petitioner’s account on                      
             October 21, 2002, was $1,847.97 (i.e., - $8,273 + $7,914 +               
             $1,780.65 + $989.25 + $2,627.36 - $1,780.65 - $989.25 -                  
             $420.39).                                                                
                  In the case of petitioner’s 1999 return, as shown                   
             above, petitioner filed her return on April 17, 2002,                    
             approximately 20 months after the due date.  The return                  
             showed tax of $1,864, and claimed a credit for withholding               
             of $81, for a balance due of $1,783.  Petitioner paid                    
             $1,868 with the return.  Petitioner made this payment more               
             than 24 months after the payment of her 1999 tax was due                 
             (i.e., April 15, 2000).  The amount of this payment,                     
             $1,868, is $85 more than the balance shown on the return.                




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