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On October 14, 2000, petitioner and Mr. Butner signed Form
1040 for the taxable year 1998 (1998 Form 1040). At the time
petitioner signed that form, she was aware (1) that the bank-
ruptcy judgments had been entered against Mr. Butner and herself
and had not been satisfied and (2) that respondent had issued
notices of Federal tax lien with respect to the respective
liabilities of petitioner and Mr. Butner for the taxable years
1994 and 1995. On October 18, 2000, petitioner and Mr. Butner
filed late their 1998 Form 1040. In that form, petitioner and
Mr. Butner reported self-employment tax owed of $8,935 and a
total amount owed of $8,935.
On November 20, 2000, an assessment of self-employment tax
of $8,935 was made for the taxable year 1998. On the same date,
interest of $1,484.13 and penalties of $2,903.87 were also
assessed for that year. As of November 20, 2000, the total
unpaid assessed liability for the taxable year 1998 was $13,323.
At the time in June 2003 the Appeals officer considered peti-
tioner’s request for relief under section 6015, the total unpaid
assessed liability for that year was the same amount, excluding
any addition to tax and interest accrued after November 20,
2000.8
8The parties stipulated that, at the time in June 2003 the
Appeals officer considered petitioner’s request for relief under
sec. 6015, the total unpaid assessed liability for the taxable
year 1998 was $13,327, excluding any addition to tax and interest
(continued...)
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