Kevin F. Foley and Shula K. Foley - Page 2
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Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
At the time of filing the petition, petitioners resided in
In 1999, petitioners earned $359,378 in short-term capital
On September 7, 2000, petitioners purchased a new residence
for $140,000 with a $40,522 cash down payment and a contract for
deed for the balance with a balloon payment due on June 1, 2007.
On or about February 21, 2005, petitioners filed late their
1999 joint Federal income tax return showing a tax liability of
$99,548. Petitioners included no payment with the return, and in
1999 petitioners paid no withholding taxes and no estimated
On or about April 4, 2005, respondent assessed the above
$99,548 tax liability reported on petitioners’ 1999 Federal
income tax return, along with interest and penalties and mailed
to petitioners a notice and demand for payment.
On or about October 10, 2005, respondent mailed to
petitioners a notice of intent to levy relating to petitioners’
1999 Federal income taxes, plus penalties and interest in the
total amount of $197,202.22.
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Last modified: November 10, 2007