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collection of petitioners’ outstanding liabilities for 1992 and
1993 has not expired. Sec. 6502(a). Accordingly, the fact that
respondent may not have taken collection action against
petitioners immediately after assessment of the liabilities in
issue is of no moment.
B. Petitioners’ Liability for Additions to Tax and Interest
We turn now to what we understand to be petitioners’
contention that the Court should review respondent’s failure to
abate additions to tax (“penalties”) and interest with respect to
1992 and 1993.
Initially, it should be recalled that petitioners filed
their 1992 income tax return some 10 months late and did not
enclose payment with their return of any part of the liability
reported thereon; consequently, respondent assessed against
petitioners an addition to tax under section 6651(a)(1) for
failure to timely file and an addition to tax under section
6651(1)(2) for failure to timely pay. Similarly, petitioners
filed their 1993 income tax return some 2 months late, did not
enclose payment with their return of any part of the liability
reported thereon, and reported liability for an “estimated tax
penalty”; consequently, respondent assessed against petitioners
an addition to tax under section 6651(a)(1) for failure to timely
file, an addition to tax under section 6651(1)(2) for failure to
timely pay, and an addition to tax under section 6654(a) for
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