Raymond Wright - Page 3

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          tax year there remained a balance due of $1,659.38 which                    
          consisted solely of interest.                                               
               Although the March 27, 2003, payment was made during the               
          pendency of petitioner’s appeal, apparently neither party brought           
          this payment (or the satisfaction of petitioner’s 1987 tax year)            
          to the attention of the Court of Appeals, nor does it appear that           
          the Court of Appeals took it into account.  Furthermore, the                
          satisfaction of petitioner’s 1987 tax year was not brought to the           
          Court’s attention until after the second trial of this case in              
          2006.                                                                       
               On October 13, 2004, the Court of Appeals issued its mandate           
          vacating and remanding the decision of this Court.  In remanding            
          this case to this Court for further proceedings, the Court of               
          Appeals ordered that such a proceeding should be confined to                
          consideration of the following issues (the four issues):  (a)               
          Whether petitioner’s 1993 tax refund was sent to him by the                 
          Internal Revenue Service (IRS) in 1994; (b) if not, whether                 
          petitioner timely received notice from the IRS that his refund              
          had not been applied to his 1987 and 1989 tax deficiencies; (c)             
          if not, whether petitioner’s current tax liability should be                
          consequently adjusted by, inter alia, an abatement of interest              











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