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On or about October 3, 1998, respondent issued to
petitioners a statutory notice of deficiency with respect to
petitioners’ 1996 income taxes. Petitioners received this
statutory notice of deficiency. Petitioners did not petition the
Court regarding the deficiency respondent determined for 1996.
On April 12, 1999, respondent assessed income tax of $7,382
and additions to tax pursuant to section 6651(a)(1) and (2) and
section 6654 for 1996.
Subsequent to respondent’s assessment for 1996, respondent
received petitioners’ delinquent tax returns for 1995, 1996, and
1997.
Petitioners’ 1995 tax return reported $3,064 of tax due.
Petitioners were not entitled to a withholding credit for 1995.
Petitioners did not remit payment when they filed their 1995 tax
return.
Based on petitioners’ 1996 tax return, respondent:
(1) Abated $3,831 of petitioners’ income tax
assessment, a portion of the additions to tax pursuant
to section 6651(a)(1) and (2), and the addition to tax
pursuant to section 6654 for 1996;
(2) allowed petitioners an additional withholding
credit of $806 for 1996; and
(3) abated $808 of assessed interest for 1996.
A withholding credit and payment submitted with petitioners’
1997 tax return fully paid the tax shown on the return.
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Last modified: May 25, 2011