- 4 - 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 "ThePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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