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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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