- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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