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Petitioners timely filed a joint Federal income tax return
for 1995 reporting a tax due of $1,586. Because petitioners had
a withholding credit of $3,435, an overpayment of $1,849
resulted, which respondent applied to the 1991 quick assessment.
On October 28, 1996, respondent collected and applied a levy
of $387.49 to the 1991 quick assessment.
Petitioners timely filed a joint Federal income tax return
for 1996 reporting tax due of $418. Because petitioners had
withholding and earned income credits totaling $2,247.58, an
overpayment of $1,829.58 resulted, which respondent applied to
the 1991 quick assessment.
On January 21, 1997, respondent collected and applied a levy
of $120.43 to the 1991 quick assessment.
Petitioners timely filed a joint Federal income tax return
for 1997 reporting tax due of $6,887. As petitioners'
withholding and excess FICA credits totaled only $2,696.69,
respondent assessed the reported tax as well as a failure to pay
addition to tax of $31.57 and interest of $43.38. On July 13,
1998, respondent abated $1,033 of the previously assessed tax.
On September 8, 2000, respondent sent petitioners a Letter
3172, Notice of Federal Tax Lien Filing and Your Right to a
Hearing Under I.R.C. 6320, indicating income tax owed of
$3,337.24 and $3,232.26 for the 1993 and 1997 taxable years,
respectively. Petitioners subsequently submitted a Form 12153,
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