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that same date, respondent assessed the 1995 income tax
liability, a late-filing penalty in the amount of $100, a failure
to pay tax penalty in the amount of $38.19, and accrued interest
in the amount of $73.03, for a total assessment of $613.25. On
November 17, 1997, respondent assessed the 1996 income tax
liability, a late-filing penalty in the amount of $333.15, a
failure to pay tax penalty in the amount of $59.23, and accrued
interest in the amount of $99.21, for a total assessment of
$1,972.25.
Events Leading to the Issuance of the Notice of Determination
On December 21, 1999, respondent mailed two separate Notices
of Intent to Levy and Notice of Your Right to a Hearing to
petitioners. The notices reflected petitioners’ unpaid Federal
income tax liabilities for 1990 through 1992 and 1994 through
1996. On January 26, 2000, petitioners informed respondent of
their desire to submit an offer in compromise to resolve all of
their individual and joint liabilities. In response, respondent
mailed petitioners a package of materials for the submission of
offers in compromise for their outstanding individual and joint
liabilities.
On April 19, 2000, respondent received petitioners’ offer to
compromise the 1994 through 1996 joint liabilities for $1,150.
On that same date respondent received petitioner’s offer to
compromise the 1990 through 1992 liabilities for $360. Both
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