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Petitioners’ 1993 Federal income tax return reported tax of
$1,781, withholding credits of $1,030, and a balance due of $751.
On July 25, 1994, respondent assessed the tax reported by
petitioners in their 1993 return, along with penalties and
interest. However, petitioners failed to pay the amount due.
Petitioners timely filed their joint Federal income tax
returns for the years 1994, 1995, 1996, 1997, and 1999 with the
Internal Revenue Service Center in Kansas City, Missouri.
Petitioners’ 1994 Federal income tax return reported tax of
$4,184, withholding credits of $87, and a balance due of $4,097.
On June 5, 1995, respondent assessed the tax reported by
petitioners in their 1994 return, along with penalties and
interest. Also on June 5, 1995, notice and demand for payment of
the 1994 income tax liability was sent to petitioners. However,
petitioners failed to pay the amount due.
In 1995, petitioners again agreed to an installment
agreement with respondent in regard to taxable years 1990, 1991,
1992, 1993, and 1994. This agreement required petitioners to
make monthly installment payments of $200 in an attempt to pay
off their tax liabilities from 1990, 1991, 1992, 1993, and 1994.
Throughout 1996, 1997, and 1998, petitioners made several
payments of $200 in accordance with the 1995 installment
agreement. One payment recorded on petitioners’ transcript of
account for taxable year 1990 shows a payment of $3,200 made on
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