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1995 and 1996
Petitioner’s 1995 and 1996 tax returns were selected for
examination, and respondent proposed adjustments. On March 12,
1998, respondent issued a 30-day letter to petitioner for the
taxable year 1995. On the same date, respondent issued a 30-day
letter to petitioner and his wife for the taxable year 1996.
Petitioner agreed with the adjustments proposed by respondent for
1995 and signed the Form 4549-CG, Income Tax Examination Changes.
The Form 4549-CG for 1995 included a corrected liability and an
addition to tax under section 6651(a)(1). Petitioner and his
wife agreed with the adjustments proposed by respondent for 1996,
and they each signed the Form 4549-CG.
Petitioner returned the signed Forms 4549-CG to respondent,
by letter dated April 9, 1998. In the letter, petitioner asked
respondent to make further adjustments to his 1995 tax return.
Petitioner asserted that payments he received from a third party
were salary and not self-employment income as characterized by
the payor. Petitioner enclosed with the April 9 letter an
advance payment of $650, which he asked respondent to apply to
his “past due self-employment tax” for the 1995 tax year.
Respondent applied the $650 payment to petitioner’s 1995 tax
liability on April 13, 1998.
In the April 9, 1998, letter, petitioner also requested that
respondent prepare an installment agreement because petitioner
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