Sam E. Scott - Page 3




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               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 had               







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