- 5 -
account), $1,689.81, and $1,047.02, respectively. Although the
1999 check was not paid until June 10, 2003, credits for the
applications to 1998, 1999, and 2002 were given as of June 2,
2003, the date respondent received the 1999 check.
Needless to say, because the majority of the proceeds of the
1999 check were applied to his 1998 tax liability, petitioner’s
1999 liability went largely unpaid. On or about January 12,
2004, petitioner was notified by respondent that his then 1999
income tax liability, including interest and additions to tax,
totaled $17,504. Up until that time, petitioner considered his
1999 liability to have been paid by the 1999 check. In response
to his inquiry regarding his 1999 liability, petitioner was
advised in respondent’s letter dated March 15, 2004, as to how
the proceeds of the 1999 check were applied.
Following receipt of respondent’s explanation, in a letter
dated April 9, 2004, petitioner requested that respondent abate,
fully or partially, “penalties”4 to tax applicable for 1998, 1999,
and 2002 because he “paid the full amount of all taxes owed and
interest due for those years before making this request.” In
that letter petitioner also referenced, without providing any
detail, “significant personal financial problems”. By letter
4 Various references to “penalties” that occur in various
places in the record actually are to additions to tax under sec.
6651(a)(1) and (2). References in this opinion to “additions to
tax” relate to one, or the other, or both additions, as
appropriate.
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