David Jackson and Betty S. Jackson - Page 4

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               Petitioners resided in Rancho Santa Margarita, California,             
          at the time that the petition was filed with the Court.                     
               A.  Petitioners’ Income Tax Returns                                    
               Petitioners filed Federal income tax returns for each year             
          in issue reporting tax due as follows:                                      
                                   Extension of                                       
               Tax Year Date Filed Time to File  Tax Due                              
               1995     04/15/1996 -0-           $4,528                               
               1996     09/22/1997 08/15/1997    2,327                                
               1998     12/29/1999 08/15/1999    10,965                               
               1999     10/15/2000 08/15/2000    2,431                                
               2000     10/12/2001 10/15/2001    26,144                               
               2001     04/15/2002 -0-           1,826                                
          At the time that they filed each return, petitioners did not pay            
          the tax shown as due on the return.                                         
               Based on the returns filed by petitioners, respondent                  
          assessed the tax shown as due on each return, statutory interest            
          for the years in issue, an addition to tax for failure to timely            
          file a return under section 6651(a)(1) for 1996, 1998, and 1999,            
          an addition to tax for failure to timely pay tax under section              
          6651(a)(2) for the years in issue, and an addition to tax for               
          failure to pay estimated tax under section 6654 for the years in            
          issue.                                                                      
               On May 27, 1999, petitioners entered into an installment               
          agreement for 1995 and 1996, but defaulted on April 29 and March            
          25, 2002, respectively.  On January 20, 2002, petitioners entered           
          into an installment agreement for 1998, 1999, and 2000, but                 
          defaulted on April 29, 2002.                                                






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