Christopher Kiley - Page 4

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          $1,272 and an “estimated tax penalty” (i.e., addition to tax                
          under section 6654(a)) in the amount of $40.                                
               Petitioner and his wife did not enclose payment with their             
          return of the amount reported as owed on their return.                      
               On May 20, 1996, respondent assessed the tax liability                 
          reported by petitioner and his wife on their 1995 return (i.e.,             
          $4,143), together with the “estimated tax penalty” reported                 
          therein.  On that date, respondent also assessed (1) an addition            
          to tax under section 6651(a)(2) for failure to pay and (2)                  
          statutory interest.                                                         
               Petitioner and his wife satisfied their outstanding                    
          liability for tax, additions to tax, and statutory interest                 
          through a series of installment payments, which was completed in            
          July 1997.                                                                  
               By notice dated September 10, 1997, respondent determined a            
          deficiency in the Federal income tax of petitioner and his wife             
          for 1995 in the amount of $226.4  No petition for redetermination           
          was filed with the Court.  See sec. 6213(a).  Accordingly, on               
          February 9, 1998, respondent assessed the deficiency, together              
          with (1) an addition to tax under section 6652(b) for failure to            
          report tip income and (2) statutory interest.  On that same day,            
          respondent sent petitioner and his wife a statutory notice of               

               4  The deficiency in income tax appears to have been based             
          principally (if not exclusively) on respondent’s determination              
          that petitioner underreported tip income for 1995.                          

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