- 12 - Payments Petitioner & John’s Total 1995 John’s Federal Income Taxes, Penalty, Joint Petitioner Estate Additions to Tax, & Interest $12,657 $8,234 $12,663 $33,554* * Respondent’s certificate of assessment reflects that petitioner and John’s total 1995 Federal income tax liability and related amounts as determined by respondent consist of the $17,516 tax underpayment, the $6,452 tax deficiency, the $1,290 accuracy-related penalty, two separately assessed sec. 6651(a)(2) failure-to-pay additions to tax of $513 and $3,004, and interest of $4,779, all totaling $33,554. For years following 1995, petitioner has made a good faith effort to comply with the Federal income tax laws. On February 24, 2004, petitioner requested relief under section 6015(b), (c), and (f) from her joint 1995 Federal income tax liability, including penalty, additions to tax, and related interest paid. On May 26, 2004, respondent’s Compliance Office proposed to grant petitioner full relief from liability for the underpayment and deficiency under a combination of section 6015(f) and (b), as follows, subject to any applicable refund limitations under Rev. Proc. 2003-61, sec. 4.04(2), 2003-2 C.B. 296, 299: Nature of Amount of Compliance Office Proposed Relief Liability Liability Amount* Basis for Underpayment $17,516 $17,516 Sec. 6015(f) Deficiency $ 6,452 $ 6,452 Sec. 6015(b) * Plus additional amounts for the related penalty, additions to tax, and interest.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011