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Year Tax
1991 $2,794
1992 1,144
1993 859
1994 1,527
1995 544
Total 6,868
Petitioners did not pay any tax with their returns for 1991-95.
Respondent assessed the tax which petitioners reported on
their return for 1995 on May 19, 1997, for 1991 and 1994 on May
26, 1997, and for 1992 and 1993 on June 30, 1997. Respondent
also assessed additions to tax for failure to timely file under
section 6651(a)(1) and failure to pay the tax shown on the return
under section 6651(a)(2) as follows:
Additions to tax
Year Sec. 6651(a)(1) Sec. 6651(a)(2)
1991 $403.65 $448.50
1992 257.40 286.00
1993 193.28 167.51
1994 343.58 198.51
1995 100.00 28.63
Total 1,297.91 1,129.15
On June 2, 1997, petitioners gave respondent a check in the
amount of $584.36 to be applied to their balance due for 1996.
The issuing bank did not honor this check.
C. Events Occurring From April 17, 1997, to March 18, 1999
Petitioners filed their returns for 1991-95 on April 17,
1997. Petitioner knew in 1997 and early in 1998 that petitioners
had not paid the taxes they reported were due on those returns.
He believed that petitioners had not correctly reported their tax
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