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On June 4, 2001, respondent assessed the tax reported on
petitioner’s 2000 tax return as well as statutory interest and a
section 6651(a)(2) addition to tax. That same day, respondent
issued to petitioner a statutory notice of balance due. On June
26, 2001, petitioner made another $10,000 payment toward his
unpaid 2000 tax liability.
On July 20, 2001, petitioner entered into an installment
agreement with respondent. The record does not disclose the
details of the agreement, but beginning on September 20, 2001,
petitioner began making monthly payments to respondent. Between
September 20, 2001, and January 27, 2003, petitioner made
payments totaling $52,600 toward his unpaid 2000 tax liability.
Petitioner did not make any voluntary payments toward his 2000
tax liability after January 27, 2003.
On October 18, 2002, respondent assessed the tax reported on
petitioner’s 2001 tax return, as well as statutory interest and
sections 6651(a)(2) and 6654 additions to tax. The record does
not disclose whether petitioner made any payments toward his 2001
tax liability.
On or around May 29, 2003, petitioner submitted an offer-in-
compromise to respondent. The record does not disclose the
3(...continued)
he disposed of shares received as a result of the exercise of his
incentive stock options before he had held them for 1 year.
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Last modified: March 27, 2008