- 2 - under section 66731 (respondent’s motion).2 We shall grant respondent’s motion. Background The record establishes and/or the parties do not dispute the following. Petitioners resided in Henderson, Nevada, at the time they filed the petition in this case. On August 17, 2000, petitioners filed jointly a Federal income tax (tax) return for their taxable year 1999 (1999 joint return). In their 1999 joint return, petitioners reported total income of $123,867 and tax due of $18,410. Although petitioners attached to their 1999 joint return Form 1040-V, Payment Voucher, reflecting a payment of $18,410, they did not remit any such payment with that return. On September 11, 2000, respondent assessed petitioners’ tax, as well as any penalties and interest as provided by law, for their taxable year 1999. (We shall refer to any such unpaid assessed amounts, as well as interest as provided by law accrued after September 11, 2000, as petitioners’ unpaid liability for 1999.) 1All section references are to the Internal Revenue Code in effect at all relevant times. All Rule references are to the Tax Court Rules of Practice and Procedure. 2Although the Court ordered petitioners to file a response to respondent’s motion, petitioners failed to do so.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011