Thomas and Julia Bo - Page 4

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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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