94-0024
Income
Signed 9/13/94
BEFORE THE UTAH STATE TAX
COMMISSION
____________________________________
XXXXX, )
:
Petitioners, : ORDER
:
v. : Appeal No. 94-0024
:
COLLECTION
DIVISION OF THE : Account No. XXXXX
UTAH STATE TAX COMMISSION, :
:
Respondent. : Tax Type: Income
_____________________________________
STATEMENT OF CASE
This
matter came before the Utah State Tax Commission for a Settlement Conference
pursuant to the provisions of Utah Code Ann. §59-1-502.5, on XXXXX. Lisa Olpin, Administrative Law Judge, heard
the matter for and on behalf of the Commission. Present and representing Petitioner was XXXXX. Present and representing Respondent was
XXXXX.
The
Petitioners were assessed a late payment penalty and interest for the late
payment of their XXXXX income tax return.
The Petitioners allege that they filed a form TC546, together with a
payment of $$$$$ on XXXXX. They filed
their income tax return on XXXXX, which would be timely with an extension if
the amount of taxes had been paid. The
Tax Commission does not have any record of receiving the form TC546 with the
payment of $$$$$. The total amount of
tax due as shown on the return was $$$$$, and the Petitioners showed a
prepayment of $$$$$, with a balance due of $$$$$, which was enclosed with the
tax return when it was filed.
The
Petitioners were not aware of the deficiency until they received a notice dated
XXXXX making demand for payment for the balance due in amount of $$$$$,
including penalties and interest. The Petitioners
have provided a photocopy of the check dated XXXXX in an amount of $$$$$,
together with a photocopy of the form TC546 which they say they filed. The Petitioners represent that the check was
written on a XXXXX, and they have sufficient funds in that account so they do
not regularly reconcile their account, and did not realize the check had not
cleared the bank. Upon receiving the
notice of the amount due, the Petitioners promptly paid the full amount of the
tax, and after some further discussions with the Tax Commission, they paid the
penalty and interest on XXXXX.
DECISION AND ORDER
Based
upon the information presented at the conference, and the records of the Tax
Commission, the Commission finds sufficient cause has been shown to waive the
penalty, but the interest is not waived for the income tax return of
Petitioners for XXXXX.
This
decision does not limit a party's right to a formal hearing. However, this Decision and Order will become
the Final Decision and Order of the Commission unless any party to this case
files a written request within thirty (30) days of the date of this decision to
proceed to a Formal Hearing. Such a
request shall be mailed to the address listed below and must include the Petitioner's
name, address, and appeal number:
Utah State Tax Commission
Appeals Division
210 North 1950 West
Salt Lake City, Utah 84134
Failure
to request a Formal Hearing will preclude any further administrative action or
appeal rights in this matter.
DATED
this 13th day of September, 1994.
BY ORDER OF THE UTAH STATE TAX COMMISSION.
W. Val
Oveson Roger
O. Tew
Chairman Commissioner
Joe B.
Pacheco Alice
Shearer
Commissioner Commissioner
^^