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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and the accompanying exhibits are
incorporated herein by this reference.
At the time of the filing of the petition, petitioner
resided in Columbia, Maryland. Petitioner filed Federal income
tax returns for 1990, 1991, 1994, 1995, 1996, 1997, 1998, and
2002. Because insufficient taxes were withheld or paid with
respect to those returns, respondent assessed the following
income tax liabilities:1
1Petitioner does not dispute the underlying liabilities that
are the subject of the instant proceeding. Those liabilities
were set forth in respondent’s Form 4340, Certificate of
Assessments and Payments, for each of the taxable years in issue.
Respondent appears to have computed these liabilities by
subtracting petitioner’s payments, withholding, and excess FICA
from the sum of petitioner’s income tax, estimated tax penalty,
late filing penalty, failure to pay penalty, interest, and
fees/collection costs. We note that respondent’s trial
memorandum reported the liability for petitioner’s 1996 taxable
year as $6,648 rather than $6,448. The record demonstrates that
additional interest, penalties, and additions to tax accumulated
subsequent to the initial assessments. As of June 2, 2004,
respondent determined that petitioner owed aggregate interest
of $56,540 and penalties/additions to tax of $13,754.57.
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Last modified: May 25, 2011