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in, and an addition to tax under section 6651(a)(1) on, Mr.
Holguin’s tax for that year in the respective amounts of $3,017
and $508. In the notice with respect to Mr. Holguin’s taxable
year 1995, respondent determined a deficiency in, and additions
to tax under sections 6651(a)(1) and 6654 on, Mr. Holguin’s tax
for that year in the respective amounts of $3,170, $530, and
$109. In the notice with respect to Mr. Holguin’s taxable year
1996, respondent determined a deficiency in, and additions to tax
under sections 6651(a)(1) and 6654 on, Mr. Holguin’s tax for that
year in the respective amounts of $3,238, $810, and $172.
Mr. Holguin did not file a petition in the Court with
respect to the notices relating to his taxable years 1994, 1995,
and 1996.
On August 17, 1998, respondent assessed Mr. Holguin’s tax,
as well as additions to tax and interest as provided by law, for
each of his taxable years 19958 and 1996.9 (We shall refer to
any such unpaid assessed amounts, as well as interest as provided
by law accrued after August 17, 1998, as Mr. Holguin’s unpaid
8On Sept. 1 and 16, 1998, July 20, 2000, and Oct. 26 and 31,
2000, respondent applied payments totaling $2,462.01 to Mr.
Holguin’s account with respect to his taxable year 1995. On
Sept. 1 and 16, 1998, respondent reduced the payments respondent
had applied to Mr. Holguin’s account with respect to his taxable
year 1995 by a total of $551.98.
9On Oct. 31, Nov. 15, and Dec. 5, 2000, and Jan. 24, Feb.
22, Mar. 8, Apr. 23, and May 10, 2001, respondent applied pay-
ments totaling $1,803.78 to Mr. Holguin’s account with respect to
his taxable year 1996.
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Last modified: May 25, 2011