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On March 6, 2000, respondent assessed the total tax of
$4,024 that petitioner reported in petitioner’s 1996 filed
return, as well as additions under sections 6651(a)(1) and
(2) and 6654(a) to petitioner’s tax for 1996 of $864.45, $672.35,
and $203.38, 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 March 6, 2000, as
petitioner’s unpaid liability for 1996.)
Except for the notice of deficiency for 1996 (discussed
below) that respondent issued to petitioner and that does not
pertain to petitioner’s unpaid liability for 1996, respondent did
not issue to petitioner a notice of deficiency for 1995 or 1996.
On March 6, 2000, respondent sent to petitioner a notice of
balance due with respect to petitioner’s unpaid liability for
1996.
On or about March 13, 2000, respondent sent to petitioner a
notice of balance due with respect to petitioner’s unpaid liabil-
ity for 1995.
On or about April 26, 2000, petitioner submitted to respon-
dent a second amended return for his taxable year 1994 and an
amended return for each of his taxable years 1995 and 1996. In
each of those amended returns, petitioner reported zero income
and claimed a refund of the tax withheld for each taxable year to
which the amended return related. Petitioner attached a document
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