Bernard A. Kansky - Page 4

                                                - 4 -                                                   
            Petitioner’s Returns for 1994 Through 2001                                                  
                  Petitioner filed Federal tax returns for 1994 through 2001.                           
            For every year except 1999, petitioner failed to fully pay the                              
            liabilities shown on those returns.                                                         
            Installment Agreements                                                                      
                  Petitioner entered into one or more installment agreements                            
            that eventually covered all years at issue except 2001.  More                               
            particularly, according to respondent’s transcripts of                                      
            petitioner’s account, petitioner’s liabilities for various years                            
            were made subject to one or more installment agreements on the                              
            following dates:2                                                                           
                              Date                     Tax Years                                        
                        May 21, 1999            1994, 1995, and 1997                                    
                        Oct. 3, 1999            1998                                                    
                        Jan. 1, 2000            1996                                                    
                        Mar. 13, 2000           1987, 1990, and 1991                                    
                        Mar. 22, 2000           2000                                                    
                  According to respondent’s transcripts of petitioner’s                                 
            account, between June 1999 and March 2002 petitioner made 31                                
            installment payments of about $750 each; respondent credited                                
            these payments variously to petitioner’s 1987, 1994, and 1995                               




                  2 The record does not contain copies of any installment                               
            agreements or any detailed information about them.  It is unclear                           
            from the record whether respondent and petitioner entered into                              
            new installment agreements on these various dates or whether                                
            existing installment agreements were modified to include                                    
            additional liabilities on these various dates.                                              





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