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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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