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releasing them from all of their dischargeable debts under
Chapter 7 of the Bankruptcy Code in 1991 and 1992.2
2. Petitioners’ 1993 Income and 1993-97 Tax Returns
In 1993, petitioners had income of $105,219, including wages
of $87,026 and rental and partnership income of $22,020. Their
tax liability for 1993 was $14,302, and they had $5,952 withheld
for Federal income tax in 1993.
Petitioners timely filed their 1993-97 returns. They did
not pay tax for those years when due other than the amounts
withheld. Respondent assessed the addition to tax under section
6651(a)(2) for failure to timely pay tax (late payment addition)
of $1,413.66 for 1993 on November 28, 1994; $4,087.25 for 1994 on
November 20, 1995; $714.12 for 1995 on April 22, 1996; $686.07
for 1996 on November 17, 1997; and $192.51 for 1997 on November
16, 1998.
B. Respondent’s Efforts To Collect Petitioners’ Unpaid Tax for
1993-96
1. Revenue Officer Sims’s Contacts With Petitioners and
Petitioners’ Representative
In 1996, Revenue Officer Paul Sims (Sims) was assigned to
collect income tax petitioners owed for 1993-95. Sims was later
assigned to collect income tax petitioners owed for 1996 and
1997.
2 The record does not indicate which debts were discharged.
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