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FINDINGS OF FACT
The parties have stipulated most of the relevant facts,
which we incorporate herein by this reference. When petitioners
filed their petition, they resided in Flushing, New York.
1994 Tax Year
On their joint Form 1040, U.S. Individual Income Tax Return,
for 1994 (Form 1040), petitioners reported a $9,223 amount due
but made no remittance with their return. Respondent assessed
the amount reported on the return. On February 26, 1996,
respondent levied petitioner husband’s retirement account and
applied the proceeds to satisfy petitioners’ then-outstanding
1994 balance and to generate a $1,224.24 refund.2
After an examination, respondent issued a notice of
deficiency, determining a $3,010 deficiency in petitioners’ 1994
Federal income tax liability. Petitioners did not petition the
Tax Court to redetermine the deficiency. On June 2, 1997,
respondent assessed the $3,010 additional tax.
1996 Tax Year
On their joint Form 1040 for 1996, petitioners reported a
$1,588 amount due but made no remittance with their return.
Respondent assessed the amount reported on the return.
2 The refund was apparently attributable to certain payments
that had been made on petitioners’ 1994 account after the return
was filed but before the levy proceeds were applied.
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Last modified: May 25, 2011