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and subsequently requested another extension to file until
October 15, 1997. On October 20, 1997, respondent received
petitioner and Mr. Toppi’s joint 1996 tax return reporting a tax
liability of $15,813 and a withholding credit in the amount of
$1,253. The withholding credit was attributable to petitioner.
On June 28, 1999, respondent sent petitioner and Mr. Toppi a
Notice of Intent to Levy because they had defaulted on their
installment agreement for taxable year 1996. Petitioner and
Mr. Toppi’s 1996 tax liability, including additions to tax and
statutory interest, was fully satisfied by February 14, 2006.
The only other payment attributable to petitioner was an offset
of a $400 overpayment from petitioner’s 2002 taxable year.
Petitioner and Mr. Toppi requested an extension from
April 15 until August 15, 1998, to file their joint 1997 tax
return. Despite receiving an extension, petitioner and Mr. Toppi
filed their return 1 year later on July 30, 1999, reporting a tax
liability in the amount of $10,200 and a withholding credit in
the amount of $1,045. The withholding credit was attributable to
petitioner. No other payments have been made on petitioner and
Mr. Toppi’s 1997 tax liability except for one payment of $600
made by Mr. Toppi.
On August 2, 1999, petitioner and Mr. Toppi untimely filed
their joint 1998 tax return reporting a tax liability in the
amount of $8,513.29 and withholding credit in the amount of
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