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Our statements as to the facts are based entirely on the
parties’ stipulations of facts and exhibits, those matters that
are admitted in the pleadings, and those matters that are
admitted in the motion papers.
Background
When the petition was filed in the instant case, petitioner
resided in the State of Washington.
Petitioner received an extension of time, until August 30,
2001, to file his 2000 Federal income tax return. He filed this
tax return on August 2, 2001. Table 1 sets forth pertinent items
shown on this tax return.
Table 1
Selected Items on Petitioner’s 2000 Tax Return (Form 1040)
Line on Form 1040 Amount Shown
L.7 Form W-2 income $1,283,285
L.8a Taxable interest 26
L.13 Capital loss (3,000)
L.14 From Form 4797 2
L.17 From Schedule E (12,125)
L.22 Total income 1,268,188
L.57 Tax 478,130
L.58 Withholding 351,727
L.69 Amount owed 126,403
Petitioner did not send any payment with his 2000 tax
return.
On or about June 12, 2001, petitioner telephoned an office
of the Internal Revenue Service (hereinafter sometimes referred
to as the IRS) to find out how to request an installment payment
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