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well as an addition to tax and interest as provided by law, for
their taxable year 1997.3 (We shall refer to any such unpaid
assessed amounts, as well as interest as provided by law accrued
after May 18, 1998, as petitioners’ unpaid liability for 1997.)
On May 31, 1999, respondent assessed petitioners’ tax, as
well as additions to tax and interest as provided by law, for
their taxable year 1998. (We shall refer to those assessed
amounts, as well as interest as provided by law accrued after May
31, 1999, as petitioners’ unpaid liability for 1998.)
On May 18, 1998, and May 31, 1999, respectively, respondent
issued to petitioners notices of balance due with respect to
petitioners’ unpaid liability for 1997 and petitioners’ unpaid
liability for 1998.
On or about July 17, 2000, petitioners jointly filed an
amended tax return for each of their taxable years 1997 (amended
1997 joint return) and 1998 (amended 1998 joint return).
In their amended 1997 joint return, petitioners reported
total income of $0 and total tax of $0 and claimed a refund of
$8,199 of tax withheld. In Part II, Explanation of Changes to
Income, Deductions, and Credits, of their amended 1997 joint
return, petitioners’ explanation for amending that return (peti-
tioners’ explanation for their amended 1997 joint return) con-
3On Sept. 15, 1999, respondent applied a payment of $150 to
petitioners’ account with respect to their taxable year 1997.
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