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Petitioners’ 1997 tax return was signed by Gary and Fran
under penalties of perjury.
After an audit, on June 30, 2000, respondent mailed to
petitioners a notice of deficiency for 1997 in which respondent
treated petitioners’ 1997 tax return as a joint 1997 Federal
income tax return for petitioners and in which respondent
determined that Gary’s $25,101 in wages constituted taxable
income to petitioners, that Fran received $30,455 in nonemployee-
fee income, that Gary and Fran received $15 in interest income
and $9,693 in early retirement account distributions, and that
petitioners owed a tax deficiency of $12,061 in addition to the
$2,114 in Federal income taxes withheld from Gary’s wages. Also,
respondent determined against petitioners a $2,412 accuracy-
related penalty under section 6662(a) relating to petitioners’
1997 tax return.
Petitioners did not file a petition with this Court with
regard to respondent’s above deficiency and penalty
determinations, and on November 20, 2000, the above deficiency
and penalty, plus statutory interest, were assessed against
petitioners.
One year later, on November 20, 2001, a notice of Federal
tax lien was filed by respondent against petitioners relating to
the assessment against petitioners of the above tax deficiency
and penalty.
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Last modified: May 25, 2011