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reviewable by any other court, and this opinion should not be
cited as authority.
On April 29, 2004, respondent issued to petitioners a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330 for unpaid 1999 Federal income tax and related
liabilities. The issue for decision is whether respondent may
proceed with the collection activity proposed in that notice.
Background
Some of the facts have been stipulated and are so found. At
the time the petition was filed, petitioners resided in Lewiston,
Idaho.
As filed and relevant here, petitioners’ joint 1999 Federal
income tax return shows: (1) Adjusted gross income of $129,805,
which amount includes an $82,490 taxable distribution from an
individual retirement account; (2) a total tax liability of
$34,650; (3) withholding credits of $21,261; and (4) a tax due of
$13,794,2 which was not paid with, or following, the filing of
petitioners’ 1999 return. On May 29, 2000, respondent assessed
the tax reported on that return.
On September 12, 2001, respondent issued to petitioners a
notice of deficiency in which a $363 deficiency in their 1999
2 This amount includes a $408 estimated tax penalty also
reported on the return.
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