- 3 - Pursuant to this Court’s decision, respondent assessed a $73,053 deficiency in income tax, a $12,313 delinquency addition to tax under section 6651(a)(1), a $14,611 accuracy-related penalty under section 6662, and $72,080.39 of accrued interest. As of January 31, 2006, the outstanding balance due on petitioner’s 1991 tax liability, including penalties and interest to that date, was $288,028.05. During the period October 22, 2000, through mid-January 2004, respondent offset an aggregate amount of $772.64 against petitioner’s outstanding 1991 tax liability. The offsets were the following tax refunds claimed by petitioner and his wife on their jointly filed returns: $56.48 (claimed for 1999), $600.00 (claimed for 2000), $112.96 (claimed for 2001), and $3.20 (claimed for 2002). On or about July 15, 2004, petitioner was in touch with Revenue Officer Beth McCullough who had been assigned to collect petitioner’s outstanding 1991 tax liability. Petitioner provided Ms. McCullough with a letter along with a seven-page memorandum, dated July 15, 2004, which set forth background in support of petitioner’s request that respondent not file an NFTL with respect to his 1991 tax liability. In the memorandum petitioner explained that he was 67 years old, had practiced law in Jackson, Mississippi, for 43 years, and had a good reputation. Petitioner also outlined the status of his health explaining that he hadPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007