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On September 11, 2000, respondent assessed petitioners’ tax,
as well as a penalty under section 6662(a) 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 September 11, 2000, as petitioners’ unpaid liabil-
ity for 1998.)
On September 11, 2000, respondent issued to petitioners a
notice of balance due with respect to petitioners’ unpaid liabil-
ity for 1998.
On August 27, 2001, respondent issued to petitioners a final
notice of intent to levy and notice of your right to a hearing
(notice of intent to levy) with respect to (1) petitioners’
taxable years 1989, 1990, and 1991, (2) petitioners’ unpaid
liabilities for 1995, 1996, 1997, and 1998, and (3) a frivolous
return penalty under section 6702 with respect to petitioners’
taxable year 1999. That notice showed in pertinent part:
Unpaid Amount Additional
Form Tax from Penalty Amount
Number Period Prior Notices and Interest You Owe
1040 12/31/1989 $11,373.42 $13,944.62 $25,318.04
1040 12/31/1990 7,542.93 9,628.18 17,171.11
1040 12/31/1991 525.47 730.83 1,256.30
1040 12/31/1995 8,266.10 2,155.31 10,421.41
1040 12/31/1996 5,875.85 1,739.85 7,615.70
1040 12/31/1997 7,742.80 2,389.62 10,132.42
1040 12/31/1998 11,649.53 2,042.94 13,692.47
CIVPEN 12/31/1999 500.00 46.01 546.01
On or about September 24, 2001, in response to the notice of
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