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Petitioner also attempted to show at trial that there was an
excess amount available from the December 1997 through March 1998
levies for prior periods that should have been applied to the tax
periods under consideration here. A comparison of the records of
the County, and those of respondent, shows that the amount
ultimately withheld from her salary by the County (net of
“refunds”) was the same amount applied to satisfy her outstanding
tax liabilities for 1990, 1992, and 1993. Respondent’s records
indicate that only the amount necessary to satisfy her
liabilities was received and applied. In addition, it seems that
petitioner was given proper credit for withholding taxes for the
years at issue.
As petitioner failed to raise any other relevant issues,
the Court finds that respondent’s determination in this case
should be sustained.
Decision will be entered
for respondent.
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Last modified: November 10, 2007