- 5 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011