- 3 - Court challenging the notice of deficiency. On September 26, 1997, pursuant to an agreement between the parties, we entered a decision holding that petitioners were liable for a penalty in the amount of $13,858 pursuant to section 6662(a) for 1989 and that petitioners owed an unpaid prior assessment of $69,289 for 1989. See Summers v. Commissioner, docket No. 17005-95. On November 24, 1997, respondent assessed petitioners the section 6662(a) penalty in the amount of $13,858 for petitioners’ 1989 taxable year. Litigation Involving Petitioners and Commonwealth Land Title Insurance Company During July 1997, respondent filed a Notice of Federal Tax Lien (NFTL) against petitioners in Berks and Montgomery Counties, Pennsylvania, relating to petitioners’ unpaid tax liabilities for 1982 through 1990. Petitioners’ surname, however, was misspelled as “Hugh D. & Teresa E. Summer” on the NFTL filed in Montgomery County, Pennsylvania. On July 31, 1997, Mr. Summers sold two properties to Leemilt’s Petroleum, Inc.: (1) 270 W. Greenwich Street, Reading, Berks County, Pennsylvania (the Berks County Property); and (2) Buckert Road and Keim Street, Lower Pottsgrove Township, Montgomery County, Pennsylvania (the Montgomery County Property). Commonwealth Land Title Insurance Company (Commonwealth) insured the title on both properties for the purchaser, Leemilt’s Petroleum, Inc., and settlement on both properties was onPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011