Wesley Sherwood - Page 7

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          false information with respect to petitioner’s Federal income tax           
          withholding for 2002.3                                                      
               Petitioner filed a Federal income tax return for 2002 on               
          August 15, 2003.  He reported that he:  (1) Had an unpaid Federal           
          income tax liability of $9,313 for 2002; (2) had no Federal                 
          income tax withheld for 2002; and (3) paid no Federal income tax            
          for 2002.                                                                   
               On September 8, 2003, respondent assessed frivolous return             
          penalties in the amounts of $500 under section 6702 for each of             
          petitioner’s tax years 1999-2001.  On September 22, 2003,                   
          respondent assessed petitioner’s Federal income tax for 2002 in             
          the amount of $10,109.97.4  On October 13, 2003, respondent sent            
          a notice and demand for payment of petitioner’s Federal income              
          tax for 2002.                                                               
          H.   Notice of Tax Lien, Request for Hearing, and Later Events              
               By letter dated March 19, 2004, respondent told petitioner             
          that a notice of lien had been filed with respect to assessments            
          for unpaid tax, additions to tax, and interest for 1998, 2001,              
          and 2002, and civil penalties under section 6682 for 2002, and              


               3  Sec. 6682(a) generally provides that an individual shall            
          be liable for a civil penalty if the individual is found to have            
          made a false statement regarding the correct amount of income tax           
          withholding on wages and/or backup withholding and there was no             
          reasonable basis for the statement.                                         
               4  Respondent assessed the amount of tax that petitioner               
          reported but did not pay and additional amounts not explained in            
          the record.                                                                 




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