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with collection by levy of petitioner’s 2002 tax liability. We
decide whether respondent may proceed with the proposed levy.
FINDINGS OF FACT
Petitioner resided in Potomac, Maryland, at the time his
petition was filed in this case. He has practiced intellectual
property law for approximately 35 years. On or about April 15,
2003, petitioner, along with his spouse, timely filed a joint
income tax return for the 2002 taxable year reflecting a balance
due of $51,349.00. Petitioner paid $26,305.00 with the return,
leaving an unpaid balance of $25,044.00. Thereafter, petitioner
entered into a payment arrangement with respondent to pay the
2002 income tax liability (including penalties and interest)
according to the following schedule:
Due Date Payment
June 16, 2003 $13,348.24
Oct. 17, 2003 13,348.24
Total 26,696.48
Petitioner, rounding the agreed payments to the nearest dollar,
made electronic payments to respondent in accord with the agreed
schedule, as follows:
Approximate Payment Date Payment
June 16, 2003 $13,348.00
Oct. 17, 2003 13,348.00
Total 26,696.00
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