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1998 joint return, petitioners reported total income of $0 and
total tax of $0 and claimed a refund of $119.62 of tax withheld.
Petitioners attached to their 1998 joint return four Forms W-2
reporting wages, tips, and other compensation totaling
$58,497.84.
On May 21, 1999, respondent issued to petitioners three
notices of deficiency with respect to their taxable years 1995,
1996, and 1997, respectively, and on April 7, 2000, respondent
issued to them a fourth notice of deficiency (notice) with
respect to their taxable year 1998, all of which they received.
In the notice relating to petitioners’ taxable year 1995, respon-
dent determined a deficiency in, an addition under section
6651(a)(1) to, and an accuracy-related penalty under section
6662(a) on petitioners’ tax for that year in the respective
amounts of $11,831.50, $1,053.32, and $842.60. In the notice
relating to petitioners’ taxable year 1996, respondent determined
a deficiency in, and an accuracy-related penalty under section
6662(a) on, petitioners’ tax for that year in the respective
amounts of $9,345 and $785.80. In the notice relating to peti-
tioners’ taxable year 1997, respondent determined a deficiency
in, and an accuracy-related penalty under section 6662(a) on,
petitioners’ tax for that year in the respective amounts of
$7,405 and $1,132.60. In the notice relating to petitioners’
taxable year 1998, respondent determined a deficiency in, and an
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