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concessions,2 the issue for decision is whether respondent’s
determination to proceed with a collection with respect to
petitioners’ Federal income tax liabilities for 1991 should be
sustained. We hold that it should.
FINDINGS OF FACT
Most of the facts have been stipulated and are so found.
The parties’ stipulation of facts and the accompanying exhibits
are incorporated herein by this reference.
At the time of filing the petition in this case, petitioners
resided in East Point, Georgia.
Petitioners filed their 1991 joint Federal income tax return
(1991 return) on September 28, 1993, reporting a tax due of
$8,343, which was not paid. Respondent assessed the tax shown as
due on the 1991 return on October 18, 1993, as well as additions
to tax under sections 6651(a)(1) and (2) and 6654, plus interest
(return assessment).
On or about March 6, 1995, respondent notified petitioners
that their 1991 income tax return had been selected for
examination.
2The notice of determination that is the subject of this
action covered petitioners’ liabilities with respect to taxable
years 1985, 1991, 1997, and 1998. Respondent conceded in the
notice that his collection action with respect to 1985 was not
appropriate, and petitioners seek review herein only with respect
to 1991.
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