Alan L. Poe - Page 3

                                        - 3 -                                         
               On February 5, 2001, respondent refunded or credited4 to               
          petitioner the entire refund (i.e., $2,777.49) that he claimed in           
          his 1999 return, plus interest thereon.                                     
               On February 6, 2002, respondent issued to petitioner a                 
          notice of deficiency (notice) with respect to his taxable year              
          1999.  In that notice, respondent determined a deficiency in, an            
          addition under section 6651(a)(1) to, and an accuracy-related               
          penalty under section 6662(a) on petitioner’s tax for his taxable           
          year 1999 in the respective amounts of $9,319, $1,761, and                  
          $1,864.                                                                     
               Petitioner did not file a petition in the Court with respect           
          to the notice relating to his taxable year 1999.                            
               On July 22, 2002, respondent assessed petitioner’s tax, as             
          well as an addition to tax under section 6651(a)(1), a penalty              
          under section 6662(a), and interest as provided by law, for his             
          taxable year 1999.  (We shall refer to those unpaid assessed                
          amounts, as well as interest as provided by law accrued after               
          July 22, 2002, as petitioner’s unpaid liability for 1999.)                  
               On July 22, 2002, respondent issued to petitioner a notice             
          of balance due with respect to petitioner’s unpaid liability for            
          1999.  On August 26, 2002, respondent issued to petitioner                  


               4Respondent credited $500 of the refund claimed in peti-               
          tioner’s 1999 return in payment of a frivolous return penalty               
          under sec. 6702 that respondent imposed on petitioner with                  
          respect to his 1999 return.                                                 





Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011