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accuracy-related penalty under section 6662(a) on, petitioners’
tax for that year in the respective amounts of $8,754 and
$1,726.88.
Petitioners did not file a petition in the Court with
respect to the respective notices relating to their taxable years
1995, 1996, 1997, and 1998.
On December 13, 1999, respondent assessed petitioners’ tax,
as well as a penalty under section 6662(a) and interest as
provided by law, for each of their taxable years 1996 and 1997.
(We shall refer to those assessed amounts, as well as interest as
provided by law accrued after December 13, 1999, as petitioners’
unpaid liabilities for 1996 and 1997.)
On December 13, 1999, respondent issued to petitioners a
notice of balance due with respect to petitioners’ unpaid liabil-
ities for 1996 and 1997.
On December 27, 1999, respondent assessed petitioners’ tax,
as well as an addition to tax under section 6651(a)(1), a penalty
under section 6662(a), and interest as provided by law, for their
taxable year 1995. (We shall refer to those assessed amounts, as
well as interest as provided by law accrued after December 27,
1999, as petitioners’ unpaid liability for 1995.)
On December 27, 1999, respondent issued to petitioners a
notice of balance due with respect to petitioners’ unpaid liabil-
ity for 1995.
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