Christopher Kiley - Page 10

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               By notice dated February 25, 2000, respondent determined a             
          deficiency in the Federal income tax of petitioner and his wife             
          for 1997 in the amount of $2,951, together with an accuracy-                
          related penalty under section 6662(a) and (b)(1) in the amount of           
          $247.16.6  No petition for redetermination was filed with the               
          Court.  See sec. 6213(a).  Accordingly, on August 7, 2000,                  
          respondent assessed the deficiency, together with the accuracy-             
          related penalty and statutory interest.  On that same day,                  
          respondent sent petitioner and his wife a statutory notice of               
          balance due, informing them that they had a liability for 1997              
          and requesting that they pay that liability.  Petitioner and his            
          wife failed to pay the amount owing.                                        
               C.  Petitioner’s Tax Liability for 1998                                
               On April 15, 1999, petitioner and his wife submitted to                
          respondent a joint Form 1040, U.S. Individual Income Tax Return,            
          for the taxable year 1998.  On the Form 1040, petitioner listed             

               6  The deficiency in income tax was based on respondent’s              
          determination that petitioner and his wife received, but failed             
          to report: (1) Wages in the amount of $19,989 from Palace Station           
          Hotel and Casino; (2) wages in the amount of $16,419 from Lucky             
          Stores; (3) wages in the amount of $759 from UFCE Local 711; (4)            
          gambling winnings in the amount of $1,429 from Palace Station               
          Hotel and Casino; and (5) a capital gain in the amount of $1,250            
          from Chicago Trust.                                                         
               We note that respondent has credited petitioner and his wife           
          for the amount withheld from wages insofar as their ultimate tax            
          liability is concerned.  However, we note further that the                  
          determination of a statutory deficiency does not take such amount           
          into account.  See sec. 6211(b)(1).                                         

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