Jon David Cooksey - Page 3

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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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