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The record does not explain the nature of this additional
payment.
The tax reported on petitioner’s return for 1999 was
due and unpaid from April 15, 2000, until April 17, 2002.
By June 3, 2002, when respondent assessed the tax reported
on petitioner’s delinquent return for 1999, interest of
$310.28 had accrued on the tax (i.e., $367.60, total
interest assessed, less $57.32, interest related to the
addition to tax under section 6654(a)(2) that was later
reversed). That amount was partially satisfied by an
overpayment of tax from petitioner’s 2000 tax return in
the amount of $39.25. The balance, $271.03, continued to
accrue interest until March 29, 2004, when petitioner paid
$294.56, the balance of $271.03, plus additional assessed
interest of $23.53.
In passing, we note that the transcript of
petitioner’s account for 1999 shows that additions to tax
under section 6654(a)(1) in the amount of $401.17 and under
section 6654(a)(2) in the amount of $115.89 were assessed
on June 3, 2002, and were reversed on June 3, 2002, and
July 1, 2002, respectively, along with the interest related
thereto in the amount of $57.32.
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