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Petitioner and Mr. Toppi’s tax difficulties began around the
time petitioner returned to work. On several occasions Mr. Toppi
told petitioner that they should file for an extension to file
their joint tax return because he did not have enough money to
pay the taxes. Petitioner and Mr. Toppi requested an extension
from April 15 until August 15, 1995 to file their 1994 tax
return. On August 21, 1995, respondent received petitioner and
Mr. Toppi’s joint 1994 income tax return reporting a tax
liability in the amount of $8,515 and a withholding credit in the
amount of $598. In order to satisfy their 1994 tax liability
petitioner and Mr. Toppi made monthly payments from June 5, 1996,
through March 6, 1998. The final payment on March 6, 1998,
satisfied petitioner and Mr. Toppi’s tax liability for 1994
including additions to tax and statutory interest.
On April 15, 1996, respondent received petitioner and Mr.
Toppi’s joint 1995 tax return reporting a tax liability in the
amount of $17,117 and a withholding credit in the amount of
$1,332. In order to satisfy their 1995 tax liability, petitioner
and Mr. Toppi made monthly payments from March 6, 1998, through
July 14, 2003. The final payment on July 14, 2003, satisfied all
of petitioner and Mr. Toppi’s tax liability for 1995 including
additions to tax and statutory interest.
Petitioner and Mr. Toppi requested an extension from April
15 until August 15, 1997, to file their joint 1996 tax return
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