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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.
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