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Petitioners filed a timely petition for review under section
6330(d)(1)(A) of respondent's determination to proceed with
collection of their 1993 and 1997 Federal income tax liabilities
by means of a lien.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated herein by this reference. Petitioners were married
and resided in Baton Rouge, Louisiana, when they filed their
petition.
Petitioners timely filed a joint Federal income tax return
for 1991. On April 13, 1992, respondent assessed the $8,943 tax
reported as due, and, as petitioners had withholding and excess
FICA credits totaling $10,090.60, an overpayment of $1,147.60
resulted. The overpayment was initially applied to tax
liabilities for 1986 and 1987, but a substantial portion of this
application was subsequently reversed, and most of the
overpayment for 1991, plus interest, was refunded to petitioners
on July 19, 1993.
The Form 4340, Certificate of Assessments, Payments, and
Other Specified Matters, for petitioners' 1991 taxable year
records that the period of limitations on assessment was extended
to September 12, 1995, on July 17, 1995. According to the Form
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Last modified: May 25, 2011