-7- Income tax IRC Sec. 6651(a) IRC Sec. Year deficiency addition to tax 6654 1992 $20,106 $4,953 $613 Petitioner had a withholding credit in the amount of $295 to be credited toward the deficiency due for calendar year 1992. Discussion In light of petitioner’s “request for relief and statement of error” in his petition, referred to above, in which he requested “abatement of all excessive and wrongful IRS assessments,” and “Proper accounting of my liability,” the Court issued an Order requiring respondent to supplement his Motion in certain respects. The Order required the following: ORDERED that on or before November 18, 2005, respondent shall supplement his [summary judgment] motion with a statement showing petitioner’s current outstanding Federal income tax liabilities for the years 1988, 1989, 1990, 1991, and 1992. It is further ORDERED that the statement described in the foregoing paragraph shall: (1) Explain how the liability for each year has been computed; (2) explain why amounts listed in the “Paying Late Penalty” column (presumably the addition to tax imposed by I.R.C. section 6651(a)(3))[2] in respondent’s final notice of intent to levy, dated March 22, 2004, are not reflected in the transcripts of account attached to respondent’s motion; and (3) demonstrate the allowance of Federal income tax withholdings for 1989, 1990, and 1992 which are not taken into account in respondent’s final notice of intent to levy, dated March 22, 2004. It is further 2This is not expressly stated in the Levy Notice or the Notice of Determination.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011