- 24 - example, monies deducted from the Petitioner’s January 2000 paycheck were not applied to the taxes due until Apr 15, 2001 when the taxes for 2000 were due. Apply- ing 1/12 of the refund due for tax year 2000 evenly throughout 2000 as payments against the taxes due would significantly reduce the interest charge in this case and more fairly represent the actual amount that should be owed. * * * In addition interest in this case is eligible for abatement because the delayed payments were not due solely to the actions of the Petitioner, but were caused by bad advice from a former CPA. [Reproduced literally.] We turn first to petitioner’s contention that respondent abused respondent’s discretion in failing to abate interest on petitioner’s unpaid total 1999 liability because respondent did not apply tax withheld from wages that petitioner received during taxable years after his taxable year 1999 to his unpaid total 1999 liability at the time such tax was withheld. We reject that contention. As discussed above, any tax withheld from an indi- vidual’s wages is deemed paid by the individual on the 15th day of the fourth month following the close of the taxable year with respect to which such tax is allowable as a credit under section 31. See sec. 6513(b)(1). We turn next to petitioner’s contention that respondent abused respondent’s discretion in failing to abate interest on petitioner’s unpaid total 1999 liability because he received “bad advice” from a certified public accountant. We reject that contention. Any advice that petitioner received from a certified public accountant is not a basis under section 6404(e) on whichPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011