- 3 - After an examination, respondent issued a notice of deficiency, determining a $4,921 deficiency in petitioners’ Federal income tax for 1996. Petitioners did not petition the Tax Court to redetermine the deficiency. On February 15, 1999, respondent assessed the $4,921 additional tax. 1997 Tax Year On their joint Form 1040 for 1997, petitioners reported total tax of $1,046, withholding credits of $464, an estimated tax penalty of $29, and an amount due of $611. Petitioners remitted the $611 with their 1997 return; however, respondent applied this payment against petitioners’ outstanding 1994 balance and assessed the amount reported on their 1997 return, plus penalties and interest. Collection Action On March 6, 2000, respondent issued to petitioners a Letter 1058, Final Notice - Notice of Intent to Levy and Notice of Your Right to a Hearing for the tax years 1994, 1996, and 1997. Petitioners requested and received the referenced hearing. On April 11, 2002, respondent issued to petitioners a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330, sustaining respondent’s proposed levy. OPINION If a taxpayer fails to pay any Federal income tax liability within 10 days of notice and demand, the Secretary is authorizedPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011