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1995 married filing separate return included with his April 11,
2001, letter, plus interest and penalties. By notice dated
November 12, 2001, respondent advised petitioner that, for his
1995 tax year, he had a balance due of $84,254, after giving
credit for previous payments (except for the $25,000 payment,
which, as previously described, had been applied partly to
petitioner’s and Astrid Downing’s 1996 joint tax underpayment,
with the balance having been refunded to petitioner and Astrid
Downing).3
Petitioner’s 1999 Tax Return
On September 3, 2002, the IRS received petitioner’s
delinquent 1999 Federal income tax return, showing his address as
being in Idaho (the Idaho address). Petitioner’s 1999 return
showed that he owed $16,508, but no payment was remitted. The
IRS assessed the tax shown on the return, plus interest and
penalties, and by notice dated November 11, 2002, advised
petitioner that he owed $27,318 on his 1999 account.
First Power of Attorney
On November 4, 2002, respondent received from petitioner
Form 2848, Power of Attorney and Declaration of Representative,
3 On Aug. 30, 2002, petitioner delinquently filed his
Federal income tax returns for 2000 and 2001, showing
overpayments of $11,102 and $14,893, respectively. The record
does not reveal what address petitioner used on these returns.
In September 2002, respondent applied these overpayments against
petitioner’s 1995 liability.
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Last modified: November 10, 2007