Simon L. and Patricia M. Richard - Page 6

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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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