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income of $4,175.00, tax due of $109.00, and withholding credits
of $15,118.79.
Subsequently, respondent examined and proposed an adjustment
to the 1979 joint return. Petitioner and Levy agreed to that
adjustment. Form 4340, Certificate of Assessments, Payments, and
Other Specified Matters (Form 4340), dated September 3, 2003,
indicates that on October 10, 1988, respondent assessed 1979
income tax deficiency in the amount of $26,520.00, plus
$31,968.36 in interest. Form 4340 also indicates several future
levies and notices to levy dated between 1997 and 2001.
On May 22, 1997, petitioner and Levy executed a Form 900,
Tax Collection Waiver, extending the period of limitations for
collection of their 1979 tax liability until December 31, 2003.
The Form 900 Waiver reflected that petitioner and Levy had an
unpaid 1979 tax liability of $49,147.52 as of May 22, 1997.
Form 4340 lists, in pertinent part, the following actions
with respect to petitioner and Levy’s 1979 taxable year:
Assessment, Payment, Assessment
Explanation of Other Debits Credit Date(23C
Date transaction (Reversal) (Reversal) RAC 006)
4-15-80 Return filed & -- $109.00 5-12-80
tax assessed
4-15-80 Withholding & -- 15,118.79 --
excess FICA
4-15-80 Overpayment –- (10,000.00) --
credit elect
transferred to
next tax pd.
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