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6320 and/or 6330. Following concessions, we must decide whether
respondent is entitled to proceed by levy to collect additions to
tax under sections 6651(a)(2) and 6654 with respect to
petitioner's 2000 taxable year.
Background
Some of the facts have been stipulated and are incorporated
by this reference.
Petitioner was a resident of Scarbourgh, Tobago, British
West Indies, at the time the petition was filed. The address on
petitioner's Federal income tax return for 2000 was P.O. Box 542,
Scarbourgh, Tobago, British West Indies, which was petitioner's
residence in 2000 and continued to be so through the time of
trial.
For taxable year 2000, petitioner made two estimated tax
payments of $32,157 each on April 21, 2000, and September 23,
2000. An estimated tax remittance of $32,157 for June 2000,
however, was mistakenly placed in an envelope addressed to the
State of Missouri Department of Revenue and mailed by
petitioner's daughter, who was assisting him at his office. The
State of Missouri Department of Revenue received the check on
June 15, 2000, successfully negotiated it, and applied $32,157
against petitioner's State income tax liability for 2000.
Petitioner had no amounts withheld with respect to his Federal
income tax liability for 2000.
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