- 6 - from petitioner’s retirement account in connection with the 1998 levy (described above). In July 2001, petitioner submitted to respondent a Form 1040, U.S. Individual Income Tax Return, for 1998. Petitioner claimed that she was entitled to a prepayment credit of $53,290 for 1998--an amount that included the $24,844 figure for tax withholding referred to in the notice of deficiency and the $8,736 and $11,468 amounts respondent collected pursuant to the 1998 levy and applied to petitioner’s accounts for the taxable years 1982 and 1985. On May 22, 2002, the Court entered an agreed decision at docket No. 9419-01 which provided that petitioner was liable for a deficiency of $34,163 for 1998, as well as additions to tax of $2,097, $233, and $114 pursuant to sections 6651(a)(1) and (2) and 6654, respectively. The parties stipulated (below the signature of the Judge who entered the decision) that (1) petitioner was entitled to a prepayment credit of $24,844 for 1998, and (2) the deficiency of $34,163 was computed without taking the prepayment credit into account. No appeal was filed, and the Court’s decision at docket No. 9419-01 is long since final. Secs. 7481(a)(1), 7483. Collection Action for 1998 Although respondent sent to petitioner a number of noticesPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: March 27, 2008