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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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