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Petitioners’ 1990 Federal income tax return reported tax of
$7,462, withholding credits of $1,068, and a balance due of
$6,394. Petitioners made a subsequent payment of $1,936 which
reduced their balance due to $4,458. On May 4, 1992, respondent
assessed the tax reported by petitioners on their 1990 return,
along with penalties and interest. However, petitioners failed
to pay the amount due.
Petitioners’ 1991 Federal income tax return reported tax of
$1,905, withholding credits of $436, an earned income credit of
$203, and a balance due of $1,266. On June 1, 1992, respondent
assessed the tax reported by petitioners on their 1991 return,
along with interest. However, petitioners failed to pay the
amount due.
Petitioners’ 1992 Federal income tax return reported tax of
$2,137, withholding credits of $705, and a balance due of $1,432.
On June 7, 1993, respondent assessed the tax reported by
petitioners in their 1992 return, along with penalties and
interest. However, petitioners failed to pay the amount due.
During 1993, petitioners and respondent agreed to an
installment agreement with regard to taxable years 1990, 1991,
and 1992. This agreement required petitioners to make monthly
installment payments in an attempt to pay off their tax
liabilities from 1990, 1991, and 1992. In 1993, petitioners made
two subsequent payments of $100 under the installment agreement.
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