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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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