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The undisputed facts are that petitioner filed delinquent
returns for 1998 and 1999, and she paid the taxes reported
on those returns more than 36 months past the payment due
date in the case of the 1998 return, and more than 24
months past the payment due date in the case of the 1999
return. Respondent assessed the tax shown on each
delinquent return, together with appropriate interest,
and notified petitioner of her outstanding liability.
Petitioner did not pay her outstanding liabilities for 1998
and 1999 until approximately two years after she filed her
delinquent returns.
Furthermore, it is undisputed that respondent sent to
petitioner statutory notices of balance due and a notice of
intent to levy with respect to each of the years in issue.
The certified transcript of petitioner’s account for 1998
shows that respondent issued statutory notices of balance
due on July 8 and October 21, 2002, when the balance of
petitioner’s account was $5,038.26 and $1,847.97,
respectively. These balances are shown on the 1998 status
history of petitioner’s account, which is attached to
petitioner’s amended petition. The certified transcript of
petitioner’s account for 1999 shows that respondent issued
statutory notices of balance due on June 3 and July 1,
2002, when the balance of petitioner’s account was $884.66
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