Colorado Mufflers Unlimited, Inc. - Page 2




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          petitioner during 2000 and 2001 and that petitioner was liable              
          for Federal Insurance Contributions Act (FICA) taxes, income tax            
          withholding, and Federal Unemployment Tax Act (FUTA) taxes, the             
          section 6662 accuracy-related penalty, and the addition to tax              
          under section 6651(a)(1) in the following amounts:                          
                                        Taxable period ended 2000                     
          Tax/addition/penalty Mar. 31    June 30    Sept. 30   Dec. 31      Total    
          FICA           $6,200.18  $6,200.18  $6,200.18  $6,200.18  $24,800.72       
          Income tax          11,346.72  11,346.72  11,346.72  11,346.72   45,386.88  
          Sec. 6651(a)(1)       4,386.73   4,386.73   4,386.73   4,386.73   17,546.92 
          Sec. 6662      3,509.38   3,509.38   3,509.38   3,509.38   14,037.52        
          FUTA    ---        ---  ---      3,337.83    3,337.83                       
          Sec. 6651(a)(1)         ---        ---        ---        834.46      834.46 
          Sec. 6662               ---        ---        ---        667.57      667.57 
          Total              25,443.01  25,443.01  25,443.01  30,282.87  106,611.90   
                                        Taxable period ended 2001                     
          Tax/addition/penalty Mar. 31    June 30    Sept. 30   Dec. 31      Total    
          FICA                $6,200.17  $6,200.17  $6,200.17  $6,200.17  $24,800.68  
          Income tax          11,346.72  11,346.72  11,346.72  11,346.72   45,386.88  
          Sec. 6651(a)(1)       4,386.73   4,386.73   4,386.73   4,386.73   17,546.92 
          Sec. 6662           3,509.38   3,509.38   3,509.38   3,509.38   14,037.52   
          FUTA    ---   ---  ---     3,337.83    3,337.83                             
          Sec. 6651(a)(1)         ---        ---        ---        834.46      834.46 
          Sec. 6662               ---        ---        ---        667.57      667.57 
          Total          25,443.00  25,443.00  25,443.00  30,282.86  106,611.86       
          In his pretrial memorandum, respondent conceded that he has                 
          mistakenly applied both the section 6651(a)(1) addition to tax              
          and the section 6662 accuracy-related penalty to the periods                
          ended September 30 and December 31, 2000, and March 31, June 30,            
          September 30, and December 31, 2001, and provided the following             
          revised numbers:                                                            











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