- 3 - Petitioner finally began to get his life back on track about 3 years later, and in 1998 he filed the Brauns’ tax returns for 1994 through 1997 and submitted an offer in compromise to respondent for the outstanding tax liabilities and interest.3 Specifically, petitioner filed the Brauns’ prior 4 years of income tax returns on September 13, 1998. The Brauns were due refunds for 1995 and 1996. After crediting the refunds against their 1994 tax liability, the Brauns had tax liabilities left outstanding for 1994 and 1997. Respondent previously sent the Brauns a deficiency notice for 1994. When the Brauns failed to respond, respondent assessed an amount the Internal Revenue Service (IRS) determined to be the Brauns’ 1994 tax liability and $2,028.31 in interest.4 Respondent assessed additional tax and interest after the Brauns filed their income tax return for 1994.5 Respondent also assessed the tax reported on their income tax return for 1997 3The Brauns were due refunds for 1995 and 1996 that respondent applied against their 1994 tax liability. Income tax credits totaling $2,294.05 from 1995 and 1996 were applied to the Brauns’ 1994 account, and respondent abated $197.21 of interest. Income tax credits totaling $2,832.47 from 1999-2002 were also applied to the Brauns’ 1994 account. 4The amount assessed for 1994 included a $7,057 income tax deficiency, a $1,220.75 addition to tax under sec. 6651(a)(1) for failure to file timely, and a $239.13 addition to tax under sec. 6654 for failure to pay estimated tax. 5The late-filed return for 1994 reflected a $12,311.60 tax liability that resulted in an additional assessment for 1994 of $5,254 in tax and $1,219.06 in interest.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011