Joseph T. Hayes and Marilyn Hayes - Page 3

                                        - 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 authorized            






Page:  Previous  1  2  3  4  5  6  Next

Last modified: May 25, 2011