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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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Last modified: May 25, 2011