- 5 -
to petitioner’s taxable year 1994, as well as additions under
sections 6651(a)(1) and (2) and 6654(a)1 to that assessed tax of
$2,349.45, $2,610.50, and $531.74, respectively, and interest as
provided by law. (We shall refer to any such assessed amounts,
as well as interest as provided by law accrued after April 3,
2000, as respondent’s assessed amounts for petitioner’s taxable
year 1994.)
On or about May 1, 2000, respondent sent to petitioner a
notice of balance due with respect to respondent’s assessed
amounts for petitioner’s taxable year 1994.
Respondent accepted and processed as filed the respective
returns for 1995 (petitioner’s 1995 filed return) and 1996
(petitioner’s 1996 filed return) that petitioner mailed to
respondent on or about May 24, 1999.
On February 7, 2000, respondent assessed the total tax of
$3,566 that petitioner reported in petitioner’s 1995 filed
return, as well as additions under sections 6651(a)(1) and
(2) and 6654(a) to petitioner’s tax for 1995 of $686.47, $686.48,
and $163.41, respectively, and interest as provided by law. (We
shall refer to any such unpaid assessed amounts, as well as
interest as provided by law accrued after February 7, 2000, as
petitioner’s unpaid liability for 1995.)
1All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011