James G. & Katherine Bourekis - Page 4

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          stated that no penalties were being asserted, requested that                
          petitioners execute the Form 870 and pay the resulting tax and              
          interest due for 1981.  It appears that petitioners declined to             
          execute the Form 870.                                                       
               On October 7, 1996, petitioners submitted a check to                   
          respondent in the amount of $4,472 to be treated as an advance              
          payment of any tax deficiency thereafter found to be due for                
          1981.  Petitioners intended to terminate the running of statutory           
          interest on any deficiency for 1981.                                        
               On October 24, 1996, respondent issued a notice of                     
          deficiency to petitioners determining a deficiency in their                 
          Federal income tax for 1981 in the amount of $4,472.  The notice            
          of deficiency included a statement that interest will accrue on             
          the deficiency from the due date of the return until the date the           
          deficiency is paid.  The notice of deficiency did not include a             
          determination that petitioners were liable for any additions to             
          tax or penalties.                                                           
               Petitioners invoked the Court's jurisdiction by filing a               
          timely petition for redetermination.  At the time the petition              
          was filed, petitioners resided in Spokane, Washington.                      
               Paragraph 3 of the petition states that petitioners are                
          contesting the deficiency in the amount of $4,472, as well as               
          "penalties" under sections 6601 and 6653(a)(1) and (2) and                  
          interest.  Paragraph 4.2 includes an allegation that "The                   

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