- 3 -
Year Amount
1997 $22,141.54
1999 12,025.26
2000 11,468.46
2001 6,673.95
2002 7,027.12
Total 59,336.33
Petitioner also attached IRS account transcripts for each of the
years in issue indicating that her unpaid tax liabilities
(including interest and penalties) as of January 2007 exceeded
$61,000. Nevertheless, in her February 8, 2007, motion,
petitioner states that “Without penalties and interest the amount
in issue is $32,059.48 & does not exceed $50,000”.
On July 24, 2007, this Court held that the amount of relief
sought for purposes of section 7463(f)(1) includes the total
amount of tax, interest, and penalties, including accrued but
unassessed interest and penalties, for which relief is sought in
the petition calculated as of the date the petition is filed.
Petrane v. Commissioner, 129 T.C. 1 (2007). In Petrane, we
reasoned:
interest and penalties are generally treated as tax,
and any reference in the Internal Revenue Code to “tax”
(with exceptions not applicable to this case) shall be
deemed to include interest and penalties. Secs.
6601(e)(1), 6665(a); Schwartz v. Commissioner, 128 T.C.
at 8, table n.1.
* * * * * * *
Page: Previous 1 2 3 4 Next
Last modified: November 10, 2007