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$48,826 and $54,467 and section 6662(a) accuracy-related
penalties of $9,765 and $10,893.
Tax Court Proceeding
On January 25, 1999, petitioner and Mr. Pacheco petitioned
the Court, docket No. 1474-99, seeking a redetermination of the
deficiencies and the section 6662(a) accuracy-related penalties
for 1995 and 1996 (prior proceeding).
The Court entered a stipulated decision in the prior
proceeding on June 29, 2000, with respect to the deficiencies and
penalties for 1995 and 1996, and no appeal was filed. The
parties have stipulated that relief under section 6015 was not
raised as an issue at any time during the prior proceeding.
Taxable Year 1997
Petitioner and Mr. Pacheco filed jointly for 1997 a Form
1040 prepared by a paid preparer. RA Lunny subsequently expanded
the scope of his audit to include 1997. On March 16, 2000,
petitioner and Mr. Pacheco consented to the assessment of an
additional tax liability of $9,503 plus interest for 1997. No
penalties were assessed.
Collection Action
On June 6, 2002, petitioner filed a petition for levy action
with the Court, docket No. 9654-02L, in response to a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 dated May 10, 2002, for 1995, 1996, and 1997.
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