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from petitioners, which was not properly credited to petitioners’
account.
On June 24, 2003, respondent filed a declaration asserting
that all credits had been properly applied and that petitioners’
tax liabilities for 1985, 1986, 1988, and 1989, including accrued
interest as of April 27, 2003, amounted to $647,749.86.3 On
December 17, 2003, the District Court entered judgment in favor
of respondent and against Mr. Summers, ordering Mr. Summers to
pay respondent $647,749.86 for unpaid Federal income taxes for
years 1985, 1986, 1988, and 1989 plus interest accruing thereon
at the rate provided by section 6621 from April 27, 2003, until
paid.
Actions Against Mrs. Summers To Reduce Federal Tax Claims To
Judgment
On December 11, 2002, respondent filed a complaint against
petitioner Teresa E. Summers (Mrs. Summers) in the U.S. District
Court for the Eastern District of Pennsylvania (District Court)
seeking to reduce to judgment the income tax assessments made
against her for 1985, 1986, 1988, and 1989, United States v.
Teresa E. Summers, No. 2002-CV-9008 (E.D. Pa.). On February 10,
2003, Mrs. Summers filed an answer and cross-complaint
3Respondent’s declaration showed Mr. Summers’s unpaid tax
liabilities and total accrued interest for 1989 to be $95,284.76
and $108,586.31, respectively.
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