Dean Strom Karnaze - Page 3

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               The petition in this case was filed in response to a Notice            
          of Determination Concerning Collection Action(s) Under Section              
          6320 and/or 6330 (notice of determination) for 1996, 1997, 1998,            
          and 1999.  Petitioner does not dispute the amount of the                    
          underlying taxes and interest owed for the years in issue.  What            
          petitioner does dispute is his liability for the additions to tax           
          under section 6651(a)(1) for failure to timely file returns,                
          section 6651(a)(2) for failure to timely pay the unpaid tax                 
          reported on the returns, and section 6654 for failure to pay                
          estimated taxes.                                                            
                                     Background                                       
               The stipulated facts and the exhibits received into evidence           
          are incorporated herein by reference.  At the time the petition             
          in this case was filed, petitioner resided in Stockton,                     
          California.                                                                 
               Petitioner filed Federal tax returns for each year in issue            
          reporting taxes due as follows:                                             
               Year      Date Due       Date Filed     Tax Due                        
               1996      10/15/97       06/12/98       $4,737                         
               1997      10/15/98       04/10/99       3,644                          
               1998      10/15/99       02/24/00       7,162                          
               1999      08/15/00       04/10/01       2,079                          
               At the time petitioner filed each return, he either did not            
          pay or made only small payments toward the amounts shown as taxes           
          on the returns.  Respondent assessed the amounts reported on                








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