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her probation, petitioner was ordered to pay $250,000 toward her
outstanding 1992 through 1995 Federal income taxes, penalties,
and interest.
On her 1997 through 2001 individual Federal income tax
returns, which she late filed on November 7, 2002, and on her
timely filed 2002 individual Federal income tax return,
petitioner reported a cumulative total tax liability of
approximately $1 million. Petitioner made no payments to
respondent with her filed tax returns, nor had petitioner made
any payments via withholding or estimates.
Respondent did not audit and did not otherwise dispute
petitioner’s 1997 through 2002 Federal income taxes as reported
by petitioner on her tax returns.2
For 2003 and 2004, petitioner apparently has timely filed
her individual Federal income tax returns, and for purposes of
this collection action respondent has not questioned the tax
liabilities and tax payments reported thereon.
On September 23, 2003, respondent filed a Federal tax lien
against petitioner relating to petitioner’s assessed and unpaid
1997 through 2002 cumulative total tax liability of approximately
$1 million, and on September 26, 2003, respondent mailed to
2 Information relating to petitioner’s 1996 individual
Federal income tax return is not in the record.
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Last modified: May 25, 2011