- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011