Antonio L. and Ernestine Thomas - Page 2

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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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