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During March 1998, respondent assessed the taxes reported on, and
the interest and additions to tax related to, the 1994, 1995, and
1996 returns.
Petitioner’s 1998 Income Tax Return
Petitioner and his wife timely filed a joint income tax
return for 1998, reporting tax due of $14,768 and withholding
credits of $1,764. Petitioner and his wife did not make any
payment with the return. On May 31, 1999, respondent assessed
the tax reported on, and the interest and additions to tax
related to, the 1998 return.
Petitioner’s 1999 Income Tax Return
On February 25, 2001, petitioner and his wife filed a
delinquent joint income tax return for 1999, reporting $16,965 of
tax due and withholding credits of $3,032.3 On March 26, 2001,
respondent assessed the tax reported on, and the interest and
penalties related to, the 1999 return.
Petitioner’s Subsequent Payments
Beginning on June 4, 1999, and ending on May 4, 2001,
petitioner and his wife paid $750 per month toward their
outstanding income tax liabilities. Respondent applied $6,000 of
those payments to petitioner’s outstanding 1985 liability,
3 On Apr. 15, 2000, petitioner and his wife filed a request
for an extension of time to file, which respondent granted. A
payment of $3,500 accompanied that request.
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Last modified: November 10, 2007