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             
          Afton, Minnesota.                                                           
               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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