Michael D. Keown and Rosann C. Keown - Page 2

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          under section 66731 (respondent’s motion).2  We shall grant                 
          respondent’s motion.                                                        
               The record establishes and/or the parties do not dispute the           
               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              

               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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