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Howard Washington and Everlina Washington, pro sese.
Marie E. Small, for respondent.
CHIECHI, Judge: The petition in this case was filed in
response to a notice of determination concerning collection
action(s) under section 6320 and/or 63301 (notice of determina-
tion).
FINDINGS OF FACT
Most of the facts have been stipulated and are so found.
At the time petitioners filed the petition in this case,
they resided in New York, New York.
On December 12, 1996, petitioners jointly filed late Form
1040, U.S. Individual Income Tax Return (Form 1040), for each of
their taxable years 1994 (1994 return) and 1995 (1995 return).2
In their 1994 return, petitioners reported that they owed $6,680
in tax. In their 1995 return, petitioners reported that they
owed $8,874 in tax. When petitioners filed Forms 1040 for their
taxable years 1994 and 1995, they did not pay the respective
amounts of tax that they owed for those years.
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.
2Petitioners’ 1995 return was due on Apr. 15, 1996. The
record does not establish when petitioners’ 1994 return was due.
However, the maximum extension of time that respondent could have
granted for the filing of petitioners’ 1994 return was 6 months.
Sec. 6081(a).
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