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section 66731 (respondent’s motion).2 We shall grant respon-
dent’s motion.
Background
The record establishes and/or the parties do not dispute the
following.
Petitioners resided in Las Vegas, Nevada, at the time they
filed the petition in this case.
On or about April 13, 1998, petitioners jointly filed a
Federal income tax (tax) return for their taxable year 1997 (1997
joint return). In their 1997 joint return, petitioners reported
total income of $81,895, total tax of $11,677, and tax due of
$3,478. When petitioners filed their 1997 joint return, they did
not pay the tax due shown in that return.
On or about April 13, 1999, petitioners jointly filed a tax
return for their taxable year 1998 (1998 joint return). In their
1998 joint return, petitioners reported total income of $78,585,
total tax of $10,426, and tax due of $2,651. When petitioners
filed their 1998 joint return, they did not pay the tax due shown
in that return.
On May 18, 1998, respondent assessed petitioners’ tax, as
1All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
2Although the Court ordered petitioners to file a response
to respondent’s motion, petitioners failed to do so.
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