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On February 25, 2000, respondent issued to petitioners a
notice of deficiency (notice) with respect to their taxable year
1998, which they received. In that notice, respondent determined
a deficiency in, and an accuracy-related penalty under section
6662(a) on, petitioners’ tax for their taxable year 1998 in the
respective amounts of $11,540 and $2,158.32.
Petitioners did not file a petition in the Court with
respect to the notice relating to their taxable year 1998.
On August 7, 2000, respondent assessed petitioners’ tax, as
well as a penalty and interest as provided by law, for their
taxable year 1998. (We shall refer to any such unpaid assessed
amounts, as well as interest as provided by law accrued after
August 7, 2000, as petitioners’ unpaid liability for 1998.)
On August 7, 2000, respondent issued to petitioners a notice
of balance due with respect to petitioners’ unpaid liability for
1998. On September 11, 2000, respondent issued a second notice
of balance due with respect to that unpaid liability.
On July 3, 2001, respondent issued to petitioners a notice
of Federal tax lien filing and your right to a hearing (notice of
tax lien) with respect to their taxable year 1998. On or about
August 1, 2001, in response to, inter alia, the notice of tax
lien petitioners filed Form 12153, Request for a Collection Due
3(...continued)
v. Commissioner, T.C. Memo. 2003-46; Smith v. Commissioner, T.C.
Memo. 2003-45.
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