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4340, respondent made a "quick assessment"2 on August 28, 1995,
of $4,941 in tax and an interest assessment of $1,096.13 with
respect to petitioners' 1991 taxable year (1991 quick
assessment).3
Petitioners did not timely file a joint return for 1992.
Respondent prepared a substitute for return and on September 25,
1995, assessed income tax of $11,913, interest of $2,363.09, and
a late filing addition to tax of $2,183.
Petitioners did not timely file a joint return for 1993.
Respondent prepared a substitute for return and on March 4, 1996,
assessed income tax of $7,652, additions to tax for late filing
and failure to pay estimated tax, and interest. The parties have
stipulated that respondent issued a notice of deficiency for
1993; petitioners thereafter submitted a 1993 joint Federal
income tax return on April 17, 1996, which respondent treated as
an amended return. The amended return reported income,
withholding credits, and tax due in larger amounts than had been
initially assessed. Respondent therefore on August 12, 1996,
2 A "quick assessment" is an internal administrative term
the Commissioner uses to denote assessments made in delineated
circumstances, including where the period of limitations on
assessment will expire within 60 days. See generally Dallin v.
United States 62 Fed. Cl. 589, 599, 601-602 (2004); Koss v.
United States, 81 AFTR 2d 98-2049, 98-1 USTC par. 50,428 (E.D.
Pa. 1998); 1 Audit, Internal Revenue Manual (CCH), sec. 4.4.25 at
8477.
3 The Form 4340 for 1991 further records assessments in 1998
and 1999 totaling $1,217.36.
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