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On December 29, 1997, respondent issued to petitioner a
notice of balance due with respect to petitioner’s unpaid liabil-
ity for 1994.
On or about August 21, 1997, petitioner filed a tax return
for his taxable year 1996 (1996 return). In his 1996 return,
petitioner reported, inter alia, taxable income of $26,117 and
tax of $4,195. Petitioner did not remit any payment with that
return.
On September 22, 1997, respondent assessed petitioner’s tax
as reported in his return, as well as additions to tax under
sections 6651(a)(1) and (2) and 6654(a), and interest as provided
by law for his taxable year 1996. (We shall refer to any such
unpaid assessed amounts, as well as interest as provided by law
accrued after September 22, 1997, as petitioner’s unpaid liabil-
ity for 1996.)
On May 5, 2003, respondent issued to petitioner a notice of
balance due with respect to petitioner’s unpaid liability for
1996. On June 9, 2003, respondent issued to petitioner another
notice of balance due with respect to such unpaid liability.
Petitioner filed a tax return for his taxable year 1998
(1998 return).4 On June 22, 2001, respondent prepared a substi-
4The record does not establish what petitioner reported in
his 1998 return. The record does establish that respondent
imposed a frivolous return penalty on petitioner with respect to,
inter alia, that return.
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